AAFP Submits Recommendations for Strengthening Proposed 2019 Medicare Physician Fee Schedule

On September 5, AAFP submitted its comprehensive comments on the Centers for Medicare & Medicaid Services' proposed 2019 Medicare physician fee schedule via a 92-page letter. AAFP's comments are aimed at ensuring "CMS can implement policies that will be meaningful for beneficiaries, supportive of their Family Physicians, and improve the financial security of the program." Below are the five major changes that AAFP recommends for strengthening the proposed fee schedule:
  • Immediately implement proposed changes in documentation, but delay collapsing payment for CPT codes 99202-99205 and 99212-99215 into a single payment
  • Delay implementation of any changes to evaluation and management (E/M) policies or codes and their descriptions until AAFP and others can help CMS create new ones with values that spur comprehensive, continuous and coordinated primary care
  • Replace the primary care add-on code with a 15% pay increase for E/M services provided by physicians who list their primary practice designation as Family Medicine, Internal Medicine, Pediatrics or Geriatrics
  • Discard the proposed 50% multiple procedure payment reduction for the primary care physicians listed above
  • Work with Congress to eliminate deductible and co-insurance requirements for chronic care management codes to foster greater utilization of the codes and improve care coordination for high-need patients; the AAFP also urges a reduction in documentation requirements for these codes
MAFP is also sending a letter expressing our recommendations and concerns with the proposed rule, aligning with AAFP's position.