September 10, 2018
SUBMITTED ELECTRONICALLY VIA
http://www.regulations.gov
Seema Verma
Administrator
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1693-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, Maryland 21244-1850
Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other
Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment
Program; and Medicaid Promoting Interoperability Program (CMS–1693–P)
Dear Administrator Verma:
The undersigned members of The Patient-Centered Evaluation and Management Services Coalition
[hereinafter “the Coalition”] write to comment on the Centers for Medicare and Medicaid Services’
(“CMS”) proposed changes to Evaluation and Management (“E/M”) documentation guidelines and
payment policies as set forth in the above captioned proposed rule,1 which is intended to update the
Physician Fee Schedule (“PFS”) for CY 2019. The Coalition appreciates the intent behind CMS’s
proposals to reduce documentation burden and we strongly urge the agency to finalize several of its
proposals to reduce that burden. However, we are very concerned about the payment proposals and
strongly urge CMS to withdraw all of its payment proposals and work closely with the coalition and
other stakeholders to consider whether there are alternatives that will improve upon the current
structure.
The Coalition strongly supports the “Patients Over Paperwork” initiative and we appreciate that CMS
understands the administrative burden attributable to the current documentation guidelines for the
new and established outpatient E/M service codes and applaud CMS for its desire to address these
issues. However, the Coalition has significant concerns and believes that waiting at least one year to
finalize any payment proposals (e.g., until 2020) will allow CMS to work with the undersigned and other
stakeholders to create a coding structure that better meets the agency’s goals of improving patient care
and reducing burden but without the undesirable consequences described below. In other words, the
coalition urges CMS to not finalize any of its E/M payment proposals, including the proposed modifier 25
reimbursement reduction policy and to withdraw any changes in outpatient visit coding or payment
until a consensus on an equitable new coding structure is achieved.
Read full letter here
