Rheumatology Leaders Respond to 2018 Medicare Physician Fee Schedule Proposed Rule July 17, 2017 Statement from Sharad Lakhanpal, MBBS, MD, President of the American College of Rheumatology “The Centers for Medicare & Medicaid Services (CMS) has released its CY 2018 Physician Fee Schedule Proposed Rule, which contains several important provisions impacting the rheumatology community. The American College of Rheumatology (ACR) is encouraged to see CMS seeking robust stakeholder input to better achieve transparency, flexibility, program simplification, and innovation with regards to reporting requirements, evaluation and management (E/M) visit codes, relative value units (RVUs), appropriate use criteria (AUC), and payment for biosimilar biological products. Such improvements are necessary to ensure rheumatology practices, especially small practices and those serving rural areas, are able to continue providing high-quality care to a growing Medicare patient population. We are particularly pleased to see that CMS recognizes the need to revise the value modifier (VM), as this program imposes a significant regulatory burden. The proposed changes would ease the automatic payment adjustment from -4 percent to -2 percent for groups of 10 or more clinicians who do not meet minimum quality reporting requirements; and from -2 percent to -1 percent for solo practitioners and groups of 2-9 clinicians. While the reductions in penalties represent a move in the right direction, the ACR believes CMS should establish a VM adjustment of zero (0) for 2018. This would align with the agency’s policy to “zero out” the impact of the Resource Use component of the Merit Based Incentive Payment System (MIPS) in 2019, the successor to the VM program. This provides additional time to continue refining the cost measures and gives physicians more time to understand the program. We also applaud the proposed delay in implementing (AUC) for diagnostic imaging studies. We will be gauging the readiness of our members to use clinical support systems and will submit comments about the proposed timeline. We support simplifying and phasing-in the program requirements. The ACR also strongly supports larger exemptions to the program - for example, for physicians in small groups and rural and underserved areas. These changes would maximize patients' access to critical diagnostic testing. However, there are several areas we would like to see CMS address, such as the quality feedback reports. The ACR believes that the process for receiving real-time feedback on performance should be simplified and streamlined, as many physicians have expressed concern that the current process is slow and unnecessarily complicated. Specifically, the rheumatology community proposes that quality and resource use reports (QRURs) be issued on a quarterly basis in a user-friendly format. We also recommend lengthening the appeal period to 90 days. The ACR is also troubled by the practice expense (PE) reimbursement cuts for injections codes. Additional reimbursement cuts could reduce Medicare patients’ access to vital injection services, especially in already underserved areas. We have long supported the creation of new evaluation and management (E&M) billing codes that accurately reflect the scope and complexity of services provided by cognitive specialists, including rheumatologists. The existing codes no longer reflect the breadth of services required by many Medicare beneficiaries, especially those with multiple chronic conditions who require extensive evaluations and treatment regimens. Furthermore, the ACR would like to see changes to the per-beneficiary payment model so that payment is based on services provided rather than specialty designation. The ACR also reiterates its support for assigning a unique J-code to each biosimilar of a particular reference product, so that physicians can better track and monitor their effectiveness and ensure adequate pharmacovigilance in the area of biosimilars. In the coming weeks, the ACR will review the rule in its entirety and submit detailed comments to CMS regarding the provisions impacting rheumatology care. We look forward to a constructive dialogue with CMS to ensure better care and lower costs for the millions of Medicare beneficiaries living with rheumatic diseases.” Media Contact: Jocelyn Givens404-633-3777, ext. firstname.lastname@example.org ###The American College of Rheumatology (ACR) is the nation's leading advocacy organization for the rheumatology care community, representing more than 9,500 rheumatologists and rheumatology health professionals. As an ethically driven professional membership organization committed to improving healthcare for Americans living with rheumatic diseases, the ACR advocates for high-quality, high-value policies and reforms that will ensure safe, effective, affordable and accessible rheumatology care.