April 23, 2019: MGMA joins in opposing H.R. 2143, the "Promoting Integrity in Medicare Act"

Chairman Richard E. Neal  
House Ways and Means Committee
1102 Longworth House Office Building
Washington, DC 20515 
 
Ranking Member Kevin Brady
House Ways and Means Committee
1139 Longworth House Office Building
Washington, DC 20515 
 
Chairman Frank Pallone
House Energy and Commerce Committee
2125 Rayburn House Office Building
Washington, DC 20515 

Ranking Member Greg Walden
House Energy and Commerce Committee
2322 Rayburn House Office Building
Washington, DC 20515

April 23, 2019

Dear Chairman Neal, Ranking Member Brady, Chairman Pallone, and Ranking Member Walden: 

The undersigned organizations write to express our strong opposition to H.R. 2143, the “Promoting Integrity in Medicare Act.” If enacted, this legislation would severely limit patient access to lifesaving services provided within coordinated care models as well as further fragment the healthcare delivery system during the transition to value-based payments and alternative payment models (APMs). 
 
The in-office ancillary services exception (IOASE) allows clinicians to provide some services in the office setting, including advanced diagnostic imaging (MRI, PET, and CT scans), radiation therapy, anatomic pathology, and physical therapy, when complex and detailed supervision, location, and billing regulatory requirements are met. In the case of diagnostic studies, in-office access to these services can facilitate immediate diagnosis and help deliver rapid, appropriate treatment of a disease condition, in a setting that is more convenient, comfortable and familiar to a patient. The benefit of providing these medical services in the physicians’ office setting is not limited to facilitating diagnoses; integration of these services facilitates the development of coordinated care models, improves communication between clinicians, offers better quality control of ancillary services and enhances data collection – all of which improves patient care and maximizes efficiencies. 

Medicare Access and CHIP Reauthorization Act (MACRA) has fundamentally transformed the delivery of healthcare. MACRA provides important opportunities to move toward value-based payment paradigms rather than the traditional fee-for-service model. A successful transition to an innovative APM requires more coordination of care within and across specialties to improve patient outcomes and reduce overall health care costs. Data shows that independent physician groups are able to create alternative payment models that are both high quality and extremely cost effective.1 Repealing the IOASE will severely restrict the ability of independent physicians to develop and participate in these new innovative payment models and as such is fundamentally antithetical to the goal of creating integrated care models. Indeed, restricting or eliminating the IOASE will further splinter our healthcare delivery system and make it more difficult to shift from fee-for-service to value-based payments.
 

View the full letter