December 6, 2019
Seema Verma
Administrator
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1715-P
P.O. Box 8016
Baltimore, MD 21244-8016
Re: CMS-1715-F – Medicare Program; CY 2020 Revisions to Payment Policies under the Physician Fee
Schedule and Other Changes to Part B Payment Policies
Dear Administrator Verma:
On behalf of more than 100,000 specialty physicians from 15 specialty and subspecialty societies, and
dedicated to the development of sound federal health care policy that fosters patient access to the
highest quality specialty care, the undersigned members of the Alliance of Specialty Medicine (the
“Alliance”) write in response to recently finalized policies associated with care management services and
payment for evaluation and management (E/M) visits in the aforementioned final rule.
Payment for Evaluation and Management (E/M) Visits
We are deeply concerned with CMS-finalized modifications for coding and payments for E/M services.
Our concerns center on CMS’ failure to apply the newly revised E/M values to the global surgery codes,
which was recommended by the American Medical Association (AMA) Relative Value System Update
Committee (RUC) and virtually all medical specialties. As we stated in our formal comments to the
proposed rule that, while each Alliance specialty is impacted differently (positive and negative) as a
result of the overall E/M modifications, we are concerned about the precedent CMS is setting by “delinking” E/M values from the E/M services delivered as part of the global surgery codes, while
maintaining the link between E/M values and other PFS services.
We continue to believe it is grossly inappropriate for the agency to “pick and choose” when to apply
established E/M values in the valuation of other services that incorporate E/M visits, or in this case,
based on the context in which E/M services are delivered. Part of CMS’ rationale for excluding the global
codes from the E/M update was its ongoing study of global surgery services that aims to determine the
number and level of E/M services delivered in the global period. Nevertheless, and regardless of the
number and level of E/M services that are delivered, when post-operative E/M services are furnished,
they should be valued based on the updated E/M values.
Read full letter here
