AANEM staff, with input from the Professional Practice and Quality & Patient Safety Committee members, drafted and submitted a 13-page, detailed comment letter
to the Centers for Medicare & Medicaid Services (CMS) on September 29 regarding its proposed rule
changes to Medicare’s Physician Fee Schedule and the Quality Payment Program (QPP) that addressed issues of importance to our membership. This was the third year that changes to the fee schedule and the QPP were included in the same rule.
One of the biggest areas of concerns in the proposed rule is the proposed nearly 11% reduction in the Medicare conversion factor. While the reduction is due to statutorily-mandated budget neutrality rules, AANEM urged CMS to use its expanded regulatory authority under the public health emergency powers to waive the budget neutrality requirement and/or work with Congress to temporarily suspend the requirement. AANEM also provided a detailed explanation of some erroneous assumptions made within the rule that accounted for approximately 3.5% of the budget shortfall and requested CMS recalculate those assumptions.
AANEM also noted significant concerns regarding overly broad language that proposes to expand the scope of practice on non-physician providers. While many AANEM members utilize non-physician providers in their practices and AANEM believes that these providers are an essential part of the healthcare team, AANEM urged CMS to reconsider such broad language, providing specific examples of concerns with regards to EDX testing and NM medicine.
The comment letter also addressed proposals to continue the expansion of telehealth, the impacts of the changes E/M coding and billing on EDX and NM physicians, as well changes allowing for “direct supervision” via telecommunications technology. Finally, AANEM provided extensive comments and suggestions to CMS on how to improve the performance-based payments for all physicians under the QPP, but specifically focused on concerns of NM and EDX physicians who face unique challenges due to the subspecialized nature of their practices.
“While the aims of the QPP remain laudable, the program continues to be overly complex and burdensome for all clinicians, but especially for many NM and EDX physicians who lack meaningful quality measures to choose from and who often see a patient only once for diagnostic purposes with no follow-up," said AANEM Health Policy Director Millie Suk, JD, MPP.
A final-interim rule is expected to be released sometime in November. If you have any questions or comments, please email the AANEM policy department: firstname.lastname@example.org