CHICAGO — Submitting detailed comments today on the proposed Medicare fee schedule for 2021, the American Medical Association (AMA) warned that some proposed regulations would hurt many physician practices already besieged by the pandemic.

“During the pandemic, physicians have responded heroically in the face of challenges to keeping their practices open and treating their patients. COVID-19 has exposed weaknesses in our health care system as well as opportunities for improvement,” said AMA President Susan R. Bailey, M.D. “Our comments are intended to ensure physicians can continue providing the highest quality care for Medicare beneficiaries during and after this public health emergency. To achieve this, we recommend that CMS prevent the steep budget neutrality cuts that are pending and continue the forward-looking changes for telehealth patients.”

The AMA strongly supports the Centers for Medicare & Medicaid Services’ (CMS) implementation of a new office visit policy on January 1, believing it will significantly reduce administrative burdens and better describe and recognize the resources involved in office visits. The AMA, however, is deeply concerned about the corresponding budget neutrality cuts, particularly in the face of the pandemic that has resulted in physician practices experiencing severe reductions in revenue. The proposal, drafted before the pandemic, would result in a 5.5 percent cut to physician payment, and additional CMS proposals would lead to an escalation of this cut to almost 11 percent. The AMA urges CMS to use its authority to waive budget neutrality and avert the cuts.

Second, the AMA recommends that CMS treat all physicians fairly by implementing the office visit increases into the surgical global payments. The AMA supports the RUC recommendations that post-operative visits should be valued equivalent to stand-alone visits. The AMA also recommends postponing implementation of the office visit add-on code until it can be better defined by the Current Procedural Terminology (CPT) Editorial Panel.

Third, CMS improved patient access during the pandemic by offering flexibility for telehealth policies, enabling patients to get much-needed care. Patients and physicians now understand the value and importance of telehealth. Consequently, the AMA urges CMS to make permanent several telehealth services, to remove geographic and site-of-service barriers, and to continue covering services through the end of the year following the year in which the pandemic ends. These services should include audio only visits.

Fourth, CMS should implement and pay for new CPT code 99072 that was sparked by the public health response to COVID-19, The additional supplies and clinical staff time to perform safety protocols described by code 99072 allow for the provision of evaluation, treatment or procedural services during a public health emergency in a setting where extra precautions are taken to ensure the safety of patients as well as health care professionals.

Fifth, CMS has introduced much-needed flexibility to the Medicare Quality Payment Program during the pandemic. CMS should continue the policies introduced during the pandemic through next year as the public health emergency is ongoing and disrupts any fair evaluation of physician performance.  CMS has listened to physicians by introducing a potentially more clinically relevant, less burdensome approach with the Merit-based Incentive Payment System Value Pathways (MVPs), and the AMA continues to work closely with CMS to ensure successful implementation of MVPs.

“Physicians have made unique sacrifices during the pandemic. They have faced personal dangers often without enough personal protective equipment. CMS has given physicians flexibility so they can continue seeing patients. We need to keep these changes in place as COVID is still presenting challenges every day,” Bailey said.