The American College of Physicians (ACP) appreciates that the final Medicare Physician Fee Schedule and the Quality Payment Program (QPP) rules for 2019 are responsive to many of the concerns that ACP raised with the Centers for Medicare and Medicaid Services (CMS).

"Internists appreciate CMS' decision not to finalize changes in payments for evaluation and management (E/M) services until 2021. We are hopeful that the additional two calendar years leave time for physicians and other health care stakeholders to work together with regulators to develop and test alternatives that preserve higher payment for more complex, cognitive care,'" said Ana María López, MD, president, ACP.

"We are pleased that CMS will be moving forward with plans to simplify documentation for such visits, with significant improvements going into effect next year, and with additional streamlined documentation options becoming available later," said López.

Health care stakeholders

"While we are encouraged that CMS has recognized the principle that more complex, cognitive care should be reimbursed at a higher level by paying more for level 5, we have reservations about paying level 4 visits, the second most complex visits, at the same amount as levels 2 and 3 visits," Dr. López continued.

"We look forward to working with CMS on developing, piloting, and evaluating approaches that recognize the value of complex, cognitive care," Dr. López said.

ACP is encouraged to see CMS incorporate several of our recommendations in the physician fee schedule final rule; however, ACP also expresses continued reservations about some of the final provisions. ACP's recommendations include:

1. ACP is strongly supportive of provisions that would reduce documentation requirements for physicians, reducing unnecessary administrative burdens. ACP thanks CMS for eliminating redundancies and only requiring physicians to document changed information since the last visit for established patients-starting right away in 2019.

Additionally, ACP is glad to see that the documentation changes would eventually allow physicians to choose between different options to best fit their practice needs, including enabling them to document based solely on medical decision making. However, these options will not be available until 2021–we would support CMS allowing them to be implemented sooner.

2. ACP is pleased to see that, effective in 2021, CMS has allowed for add-on codes for level 2-4 visits in primary care and certain specialties and for extended visits to account for the value of cognitive work in treating more complex patients. ACP especially appreciates that the changes to the add-on codes equalize primary care payments to specialty payments.

3. ACP is grateful that CMS is not moving forward with proposals to implement the Multiple Procedure Payment Reduction (MPPR).

4. ACP is strongly supportive of payments for new codes for non-face-to-face visits that will be implemented in 2019. Virtual check-ins, e-consultations, and remote evaluation of patient images and videos will improve patient access to care and help control costs.