Page 24 - Layout 1

TMA FEATURE

75 WAYS

the Big Medicare Changes Are
VERY BAD

for Physicians and Patients

By Steve Levine

he Texas Medical Association cried foul on that claim with Since its inception, physicians have complained that the QPP —
T a painstakingly detailed comment letter it delivered to CMS. with its multiple, rapidly changing data elements, measures, objec-
“We fear that the rule will significantly increase
tives, activities, thresholds, deadlines, reporting periods, and sub-
Medicare’s administrative burden, will reduce Medicare payments mission mechanisms — is a bureaucratic nightmare.
to many physician practices, will do little to improve quality of care “As we move into the third year of the QPP, TMA continues
or reduce the cost of care, and will further reduce Medicare bene- to be concerned that the compliance, documentation, and data
ficiaries’ access to care,” John G. Flores, MD, chair of TMA’s Coun- submission requirements required by law and regulation are costly
cil on Socioeconomics, and Jeffrey B. Kahn, MD, chair of the and wasteful with no proven evidence of benefit,” Drs. Flores
Council on Health Care Quality, wrote in their introduction to the and Kahn wrote.
58-page letter. “We remind CMS that with each measure, objective, and improve-
This year, the agency combined two historically complex and con- ment activity it subjects physicians to under the QPP, physicians
troversial Medicare rule proposals into a single 1,453-page docu- must spend more time on paperwork to document every aspect of
ment covering the annual Physician Fee Schedule update and clinical care delivery that corresponds to the data elements that sup-
revisions to the Quality Payment Program (QPP). port each metric.”
TMA’s analysis found extensive problems in both parts of the Failure to comply, TMA pointed out repeatedly, exposes practices
proposed rule. The association offered 75 distinct recommendations to Medicare payment cuts and costly audits.
for improvement. “While we acknowledge that many physician practices are in a
TMA welcomed CMS’ proposal to simplify the “outdated, exces- position to engage in full participation, we continue to hear from
sive, and overwhelming” documentation requirements associated even more physicians who are neither ready nor have the time and
with evaluation and management (E&M) services. resources to take on and manage the additional administrative, tech-
But the association rejected the agency’s plan to collapse the five nological, and financial challenges associated with the QPP while
levels of E&M office-visit payments to two levels, with one payment being subject to annual Medicare payment penalties due to nonpar-
rate for level 1 visits and another covering levels 2-5. The rule proj- ticipation,” the association noted.
ects the higher payment level to fall between the payment for levels
3 and 4 in the current structure — meaning physicians who typically TMA proposed delays, or major changes, to CMS’
handle level 4 and 5 visits for more complex patients would see their plans to, among many other things:
payments take a hit. • Pay for physician consultations with patients by telephone
“While CMS is proposing to reduce the E&M documentation re- or telehealth;
quirements, the amount of time, expertise, and skill used with the
patient will not change,” Drs. Flores and Kahn wrote. “This is a sig- • Not change the payment localities used in calculating the
nificant devaluation of the physician’s work.” Geographic Pricing Cost Index ;

24 San Antonio Medicine • October 2018