The American Medical Association (AMA) submitted comprehensive comments today to the Centers for Medicare & Medicaid Services (CMS) that outlined recommended changes to the proposed rule on physician payment policies.

In its comments, the AMA compliments CMS for some of the changes - most notably, the regulations that target excessive paperwork - as well as policy changes in digital medicine and alternative payment models.

The AMA's comments also elaborate on concerns that the AMA and 170 other medical organizations expressed recently about changes to Evaluation and Management (E/M) services. If the proposed rule were adopted, the sickest patients - and the physicians who treat them - would encounter significant obstacles to care.

"This provision in the proposed rule should be filed under the category of unintended consequence - or good intentions that go awry," said Dr. Barbara L. McAneny, MD, president of the AMA. "While CMS started out with the laudable goal of reducing paperwork and allowing physicians to spend more time with their patients, the cascading impact of such regulations would be bad for patients and physicians."

The AMA believes that CMS has proposed several important improvements, and the nation's largest physician organization welcomes the agency's emphasis on simplification. The effort to streamline documentation requirements will reduce note bloat, improve workflow, and contribute to a better environment for health care professionals and their Medicare patients.

Regarding the proposal to collapse payment rates for eight office visit services for new and established patients down to a total of two, that is where the unanswered questions linger. As written, they would hurt physicians who treat the sickest patients as well as those who provide comprehensive primary care, ultimately jeopardizing patients' access to care. The AMA does not think that the authors of this rule intended to limit coverage for patients who require complex services, but that would be the result. The AMA letter urges CMS to set aside this part of the proposal.

The AMA has convened a working group comprised of a broad spectrum of health professionals to come up with a better alternative that could be implemented in 2020. It is already meeting and communicating with CMS.

"The agency has been a willing listener, and we think there is opportunity to make this rule a plus for patients and physicians. This is complex work. Big picture proposals must work within the everyday demands facing working physicians," McAneny said.

Other comments within the 136-page response include:

• The AMA applauds the agency's proposal to expand coverage of digital medicine to include services employing remote patient monitoring.
• The AMA opposes reducing Medicare reimbursement for new drugs from Wholesale Acquisition Cost. This proposal would discourage physicians - especially those in small practices without bargaining power on prices - from using these drugs in their office treatments. As a result, Medicare patients would have decreased access to new and innovative therapies that are more effective and/or less debilitating than existing drugs.
• The AMA supports proposed revisions to ease the documentation burden on teaching physicians. The proposed rules would allow medical records to show that the teaching physician was present at the time the service was furnished, and such documentation may be made by a physician, resident or nurse. In addition, the extent of the teaching physician's participation in each patient's care may be documented by a physician, resident or nurse, and no longer needs to be documented personally by the teaching physician.
• The AMA continues to urge CMS to move toward a simplified scoring methodology for MIPS so that physicians can spend less time on reporting and more time with patients.
• The AMA applauds CMS' overhaul of the Advancing Care Information (ACI) category and supports many of the proposals within the Promoting Interoperability (PI) program.
• The AMA appreciates and urges CMS to finalize several of the proposed policies for alternative payment models, such as the proposal to maintain the revenue-based financial risk requirement at no more than 8 percent for an additional four years. The AMA also urges CMS to increase the availability of well-designed alternative payment models under the Quality Payment Program.
• The AMA supports CMS' proposals to expand the opportunities for physicians to qualify for the low-volume threshold in 2019 and to allow practices to opt-in to participate in the MIPS program or create virtual groups.
• The AMA is disappointed that CMS did not reduce the number of quality measures physicians must report under MIPS - a move that would immediately reduce red tape and administrative burden. Without this reduction, the AMA does not support the rule's immediate removal of the proposed measures. Also, the AMA urges CMS to retain a 10 percent weight for the cost category and remain flexible on weights for the next four years while the eight new episode-based cost measures are evaluated and more are developed and piloted.