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Seema Verma
Administrator Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Attention: CMS-1693-P
Mail Stop C4-26-05
7500 Security Boulevard
Baltimore, Maryland 21244-1850

Re: Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program (CMS–1693–P)

Dear Administrator Verma:

The undersigned members of The Patient-Centered Evaluation and Management Services Coalition [hereinafter “the Coalition”] write to comment on the Centers for Medicare and Medicaid Services’ (“CMS”) proposed changes to Evaluation and Management (“E/M”) documentation guidelines and payment policies as set forth in the above captioned proposed rule, 1which is intended to update the Physician Fee Schedule (“PFS”) for CY 2019. The Coalition appreciates the intent behind CMS’s proposals to reduce documentation burden and we strongly urge the agency to finalize several of its proposals to reduce that burden. However, we are very concerned about the payment proposals and strongly urge CMS to withdraw all of its payment proposals and work closely with the coalition and other stakeholders to consider whether there are alternatives that will improve upon the current structure.

The Coalition strongly supports the “Patients Over Paperwork” initiative and we appreciate that CMS understands the administrative burden attributable to the current documentation guidelines for the new and established outpatient E/M service codes and applaud CMS for its desire to address these issues. However, the Coalition has significant concerns and believes that waiting at least one year to finalize any payment proposals (e.g., until 2020) will allow CMS to work with the undersigned and other stakeholders to create a coding structure that better meets the agency’s goals of improving patient care and reducing burden but without the undesirable consequences described below. In other words, the coalition urges CMS to not finalize any of its E/M payment proposals, including the proposed modifier 25 reimbursement reduction policy and to withdraw any changes in outpatient visit coding or payment until a consensus on an equitable new coding structure is achieved.

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