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HAP Outlines Priorities for Physician Payment Policy

September 11, 2018

This week, HAP provided feedback for newly proposed policies that will impact how physicians are paid and seek to promote the goals of an initiative to encourage providers to focus on “Patients over Paperwork.”

In a letter to the Centers for Medicare & Medicaid Services (CMS) responding to 2019 Medicare Physician Fee Schedule proposed rule, HAP applauded efforts to:

  • Reduce administrative burdens placed on physicians including streamlining documentation requirements and offering additional flexibility in the Quality Payment Program
  • Expand access to virtual care and telemedicine

HAP urged CMS to:

  • Spend additional time analyzing and considering stakeholder feedback in newly proposed policies that would significantly change the payment of evaluation and management (E/M) services provided through outpatient and office visits
  • Ensure payment policies reflect an appreciation for the cost of supporting hospital-level care

The proposed rule suggests commonsense changes to the way physicians are required to document certain things in a patient’s medical record. For instance, HAP urged CMS to finalize the proposal to eliminate the requirement that physicians must re-document information that has already been documented in a patient’s record by practice staff or the patient. These efforts to minimize the documentation burden will free up time for clinicians to focus on caring for patients.

CMS also has proposed important efforts to leverage technology to allow proactive treatment of Medicare beneficiaries. HAP is hopeful the following policies will be finalized:

  • Allowing a physician to use communication technology to conduct a brief, non-face-to-face check-in with an established patient to determine if an office visit or other service is warranted
  • Permitting the remote evaluation of patient-transmitted information via a video or image to consider if a patient needs an office visit or other service
  • Encouraging inter-professional consultations using a telephone or the internet
  • Allowing clinical staff, including registered nurses and medical assistants, to manage remote patient monitoring services

More broadly, HAP called for Congress and the Administration to continue to expand Medicare coverage of telemedicine, such as by a presumption that Medicare-covered services also are covered when delivered via telemedicine unless CMS determines on a case-by-case basis that such coverage is inappropriate.

Despite positive movement in addressing administrative burdens, a new proposal that would change the way E/M services are paid raises concerns that payment rates would not reflect the resource use and intensity of physician services. HAP urged CMS to engage stakeholders in efforts to redesign payment for outpatient and office visits that ensure accurate payments reflecting the resources used to provide services. Ninety members of the U.S. House of Representatives, including four from Pennsylvania, sent a letter to CMS last week highlighted concerns with the proposed E/M payment policy and urged the agency to “take additional time to work closely with physicians and other stakeholders to identify alternative approaches that would accomplish CMS’ goals while ensuring physicians are reimbursed appropriately according to the level of the care required by each individual patient’s condition.”

Finally, HAP expressed continued concerns regarding payment policies that reduce payment for care provided in community-based outpatient settings. If finalized, hospitals will continue to see outpatient payments cut at the same time they are working to shift patients from more costly inpatient care to community-based outpatient services that are tailored to the needs of their communities and more convenient and accessible for patients.

HAP will continue to engage with federal policymakers as the regulatory process moves forward, and Congress provides guidance regarding Congressional priorities.

For more information about the proposed rule, please contact Kate Slatt, HAP’s senior director, innovative payment and care delivery, or Laura Stevens Kent, HAP’s vice president, federal advocacy.

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