SHM Signs onto Multi-Stakeholder Letter to CMS

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August 27, 2018

The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445–G
200 Independence Avenue, SW
Washington, DC 20201

Re: Medicare  Physician Fee Schedule for CY 2019 (CMS-1693-P)

Dear Administrator Verma:

The undersigned organizations representing physicians and other health professionals welcome and strongly support the Centers for Medicare & Medicaid Services’ (CMS) “Patients Over Paperwork” initiative. We appreciate your outreach to our community and are solidly behind your goal of reducing administrative burdens for physicians and other health care professionals so that they can devote more time to patient care. The proposals included in the 2019 Medicare physician payment rule demonstrate that you listened to our members’ concerns about the significant administrative burdens due to the documentation requirements associated with Evaluation and Management (E/M) services. We are grateful for your efforts to simplify these requirements and reduce their associated red tape.

Excessive E/M documentation requirements do not just take time away from patient care; they also make it more difficult to locate medical information in patients’ records that is necessary to provide high quality care. Physicians and other health care professionals are extremely frustrated by “note bloat,” with pages and pages of redundant information that makes it difficult to quickly find important information about the patient’s present illness or most recent test results. Several of the documentation policy changes included in the proposed rule would go a long way toward alleviating this problem and the undersigned organizations urge immediate adoption: 

1.   Changing the required documentation of the patient’s history to focus only on the interval history since the previous visit;

2.   Eliminating the requirement for physicians to re-document information that has already been documented in the patient’s record by practice staff or by the patient; and

3.   Removing the need to justify providing a home visit instead of an office visit.

Implementation of these policies will streamline documentation requirements, 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 two each, the undersigned organizations believe there are a number of unanswered questions and potential unintended consequences that would result from the coding policies in the proposed rule. We oppose the implementation of this proposal because it could hurt physicians and other health care professionals in specialties that treat the sickest patients, as well as those who provide comprehensive primary care, ultimately jeopardizing patients’ access to care. We also urge that the new multiple service payment reduction policy in the proposed rule not be adopted as the issue of multiple services on the same day of service was factored into prior valuations of the affected codes. The proposal also has significant impact on certain services, such as chemotherapy administration, that may be an unintended consequence of altering the current practice expense methodology to accommodate the proposal.

The medical community wants to help CMS work through the complicated issues surrounding the appropriate coding, payment, and documentation requirements for different levels of E/M services. Toward that end, the undersigned organizations strongly support the American Medical Association’s creation of a workgroup of physicians and other health professionals with deep expertise in defining and valuing codes, and who also use the office visit codes to describe and bill for services provided to Medicare patients. The charge to this workgroup is to analyze the E/M coding and payment issues in order to arrive at concrete solutions that can be provided to CMS in time for implementation in the 2020 Medicare Physician Fee Schedule. A number of CMS personnel monitored the initial conversations of the workgroup and we look forward to their active participation in this process going forward.

We encourage the administration to adopt in the final rule the documentation changes outlined above. These changes reflect significant progress in your Patients Over Paperwork Initiative. Such policy modifications will significantly reduce the documentation burden so health care professionals can spend more time with patients.  We also urge the administration to set aside its office visit and multiple service proposals, fully embrace the assistance of the workgroup and work together with the medical community on a mutually agreeable policy that will achieve our shared goal of simplifying E/M documentation burdens while mitigating any unintended consequences.

Sincerely,

American Medical Association Academy of Physicians in Clinical Research Advocacy Council of ACAAI

AMDA - The Society for Post-Acute and Long-Term Care Medicine American Academy of Allergy, Asthma & Immunology

American Academy of Child and Adolescent Psychiatry

American Academy of Dermatology Association

American Academy of Facial Plastic and Reconstructive Surgery

American Academy of Family Physicians

American Academy of Home Care Medicine

American Academy of Hospice and Palliative Medicine

American Academy of Neurology

American Academy of Ophthalmology

American Academy of Otolaryngic Allergy

American Academy of Otolaryngology-Head and Neck Surgery

American Academy of Pain Medicine

American Academy of PAs

American Academy of Pediatrics

American Academy of Physical Medicine and Rehabilitation

American Academy of Sleep Medicine

American Association for Thoracic Surgery

American Association of Blood Banks

American Association of Clinical Endocrinologists

American Association of Hip and Knee Surgeons

American Association of Neurological Surgeons

American Chiropractic Association

American Clinical Neurophysiology Society

American College of Allergy, Asthma and Immunology

American College of Cardiology

American College of Chest Physicians

American College of Emergency Physicians

American College of Gastroenterology American College of Hyperbaric Medicine

American College of Medical Genetics and Genomics

American College of Medical Toxicology

American College of Obstetricians & Gynecologists

American College of Occupational and Environmental Medicine

American College of Osteopathic Internists

American College of Osteopathic Surgeons

American College of Phlebology

American College of Physicians

American College of Radiation Oncology American College of Radiology

American College of Rheumatology American College of Surgeons American Epilepsy Society

American Gastroenterological Association

American Geriatrics Society

American Institute of Ultrasound in Medicine

American Medical Women's Association

American Nurses Association

American Optometric Association

American Orthopaedic Foot & Ankle Society

American Osteopathic Association

American Pediatric Surgical Association

American Physical Therapy Association

American Podiatric Medical Association

American Psychiatric Association

American Rhinologic Society

American Society for Blood and Marrow Transplantation

American Society for Clinical Pathology

American Society for Dermatologic Surgery Association

American Society for Gastrointestinal Endoscopy

American Society for Metabolic and Bariatric Surgery American Society for Radiation Oncology

American Society for Surgery of the Hand

American Society of Addiction Medicine

American Society of Anesthesiologists

American Society of Breast Surgeons

American Society of Cataract & Refractive Surgery

American Society of Interventional Pain Physicians

American Society of Neuroimaging American Society of Neuroradiology

American Society of Nuclear Cardiology

American Society of Plastic Surgeons

American Society of Regional Anesthesia and Pain Medicine

American Society of Retina Specialists

American Society of Transplant Surgeons

American Thoracic Society

American Urogynecologic Society

American Urological Association American Venous Forum

Association of American Medical Colleges College of American Pathologists Congress of Neurological Surgeons Endocrine Society

Heart Rhythm Society

Infectious Diseases Society of America

International Academy of Independent Medical Evaluators

International Society for Advancement of Spine Surgery Medical Group Management Association

National Association of Medical Examiners

North American Neuromodulation Society

North American Neuro-Ophthalmology Society Obesity Medicine Association

Renal Physician Association

Society for Cardiovascular Angiography and Interventions

Society for Vascular Surgery

Society of American Gastrointestinal and Endoscopic Surgeons

Society of Cardiovascular Computed Tomography

Society of Critical Care Medicine

Society of Gynecologic Oncology

Society of Hospital Medicine

Society of Interventional Radiology

Society of Nuclear Medicine and Molecular Imaging

Spine Intervention Society

The American College of Medical Genetics and Genomics

The American College of Osteopathic Surgeons

The American Society of Dermatopathology The Obesity Society

The Society of Thoracic Surgeons

Undersea and Hyperbaric Medicine

California Medical Association

Colorado Medical Society

Connecticut State Medical Society

Medical Society of Delaware

Medical Society of the District of Columbia

Florida Medical Association Inc

Medical Association of Georgia

Hawaii Medical Association

Idaho Medical Association

Illinois State Medical Society

Indiana State Medical Association

Iowa Medical Society

Kansas Medical Society

Kentucky Medical Association

Louisiana State Medical Society

Maine Medical Association

MedChi, The Maryland State Medical Society

Massachusetts Medical Society

Michigan State Medical Society

Minnesota Medical Association

Mississippi State Medical Association

Missouri State Medical Association

Montana Medical Association

Nebraska Medical Association

Nevada State Medical Association

New Hampshire Medical Society

Medical Society of New Jersey

New Mexico Medical Society

Medical Society of the State of New York

North Carolina Medical Society

North Dakota Medical Association

Ohio State Medical Association

Oklahoma State Medical Association

Oregon Medical Association

Pennsylvania Medical Society

Rhode Island Medical Society

South Carolina Medical Association

South Dakota State Medical Association

Tennessee Medical Association

Texas Medical Association