Re: Policies for CY 2021 for Office/Outpatient E/M Visits in the CY 2020 Medicare
Physician Fee Schedule Proposed Rule
Dear Administrator Verma:
On behalf of the undersigned 53 organizations, we write to voice our strong opposition to the
Centers for Medicare & Medicaid Services’ (CMS) proposal, as set forth in the calendar year
(CY) 2020 Medicare Physician Fee Schedule proposed rule, not to incorporate into the global
codes the adjusted values for the revised office/outpatient evaluation & management (E/M)
codes. By failing to adopt all the American Medical Association/Specialty Society Relative
Value Scale Update Committee (RUC)-recommended work and time values for the revised
office visit E/M codes for CY 2021, including the recommended adjustments to the 10- and 90-
day global codes, CMS improperly proposes to implement these values in an arbitrary, piecemeal
fashion.
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