American Society of Plastic Surgeons
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FEDERAL | ASPS to CMS: Delay Proposed 2019 PFS and QPP Changes

ASPS joined over 600 other commenters in submitting feedback on several areas of concern with the Physician Fee Schedule (PFS) and Quality Payment Program (QPP) Proposed Rule, which was published on July 27, 2018. The Society has concerns with a plan to simplify documentation requirements for Evaluation and Management (E&M) services as well as a proposal to reduce payments by half for the least expensive procedure or visit provided the same day by the same surgeon. Perhaps most troubling was the proposal to introduce a single reimbursement rate for level 2 through level 5 E&M visit.

ASPS recognizes that documentation continues to be a burden for surgeons, which is why the Society strongly encouraged the Agency to abandon each of these proposals and to instead work with the American Medical Association to ensure the accuracy of the value of physician services, including E&M services performed the same day as a procedure.

The Agency recognized the lack of reporting during the two-year-long process of valuing care in the postoperative period. However, the Agency interpreted the lack of reporting via claims by surgeons who provide post-operative visits to mean a lack of postoperative surgical follow-up. Although plastic surgeons were one of the few specialties that routinely provided this data, ASPS encouraged the Agency to significantly increase outreach and training on the need for accurate reporting of post-operative visits before it makes additional policy changes. At a minimum, the Society encouraged CMS to conduct a more in-depth analysis of the data after an additional six months of time has elapsed.

ASPS also joined with the Alliance of Specialty Medicine in calling on the Agency to scale back its proposals to implement an Appropriate Use Criteria schematic for the ordering of advanced diagnostic imaging. Recognizing the work CMS has done to address concerns about the functionality of the Quality Payment Program, ASPS offered additional feedback on the need for relevant quality measures, minimum case reporting, and the Agency's desire to remove "topped out" measures. Additionally, the Society outlined concerns with the limited timeframe for designing and proposing new improvement activities and the Agency's desire to only allow electronic health records certified to the 2015 edition of EHR technology.

ASPS strongly opposed the Agency's proposal to allow open sharing of society-developed measures and instead requested that the Agency defer any decision until the 2022 QCDR application year. ASPS also joined with 14 medical specialty societies in requesting that CMS recognize the use of a QCDR as full participation in the QPP's promoting interoperability component of MIPS.

Currently, CMS is reviewing all comment letters received. A final rule is expected to be published in mid-November.

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