CHICAGO — The American Medical Association (AMA) responded today to policies outlined last week in the Centers for Medicare and Medicaid Services (CMS) physician fee schedule proposed rule. As with any 856-page proposed rule, the AMA finds a mix of meritorious and flawed proposals that would affect payment and delivery of Medicare.

"The annual physician fee schedule update is an opportunity for CMS to shape Medicare policy and ensure it is correctly focused on patient health," said AMA President Andrew W. Gurman, M.D. "Getting this policy right is vital, and the AMA will be submitting formal comments to CMS before the final version is released later this year. There is a lot of work ahead."

The AMA commends the decision to expand coverage of the Medicare Diabetes Prevention Program (DPP) model to Medicare patients at risk of developing type 2 diabetes. Expansion of the DPP model will help at-risk seniors and people with disabilities lower their risk factors and prevent their condition from advancing to type 2 diabetes. We are pleased that CMS has acted swiftly to begin the rule-making process to expand access to the DPP model for Medicare beneficiaries with prediabetes. Earlier this year, CMS concluded that the expanded coverage would result in significant cost savings. The proposal also underscores the important role of prevention in stemming the tide of chronic disease, and we look forward to working with the Administration to advance this effort.

The AMA also welcomes the ongoing CMS effort to work with the Current Procedural Terminology (CPT) Editorial Panel and the AMA/Specialty Society RVS Update Committee (RUC) to identify and expedite new ways to report and pay for high-value care collaboration and care management services. CMS is proposing to begin compensating physicians for existing codes for prolonged services and complex chronic care management services, as well as new codes for cognitive impairment assessment and care plan services and psychiatric collaborative care management. The AMA will continue to explore and recommend additional models of innovative care that improve the health of Medicare patients.

The AMA has serious concerns about the proposal to collect information on every 10-minute increment of patient care provided by physicians as part of activities before and after each surgery/procedure, which can occur in the hospital, office, or via email/telephone. This proposal goes far beyond Congress' intent and will be extremely and unnecessarily burdensome, not only to surgeons but to all physicians who deliver the more than 4,000 services subject to this massive proposal. This new set of regulations comes as physicians already are attempting to successfully comply with MACRA, the most significant payment system changes in the last 25 years.

The AMA also opposes CMS' plan to eliminate the physician payment increase that Congress provided for 2017 in the MACRA legislation and repurpose that money to fund a newly proposed add-on payment for services provided to patients with mobility impairments. Although the AMA supports efforts to improve access to care for patients with these and other impairments, there is no justification for funding the service with an across-the-board cut in payment rates. The proposal also raises program integrity questions and seems likely to increase out-of-pocket costs for patients with disabilities.

A more detailed comment letter will be submitted to CMS in coming months.