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    September 11, 2017  

    The Honorable Seema Verma
    Administrator
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    200 Independence Avenue, SW
    Washington, DC 20201
    Submitted via www.regulations.gov

    Re: Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program; Proposed Rule (Federal Register Vol. 82, No. 139, July 21, 2017)

    Dear Administrator Verma:

    The Medical Group Management Association (MGMA) appreciates the opportunity to submit comments on the rule, “Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2018; Medicare Shared Savings Program Requirements; and Medicare Diabetes Prevention Program,” released on July 21, 2017 with file code CMS-1676-P. We look forward to continuing to work with the Centers for Medicare & Medicaid Services (CMS) on the issues in this proposed rule.

    MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.

    In summary, we urge CMS to:

    • Remove administrative barriers to billing care management services by aligning the codes with the CPT Editorial Panel guidelines, eliminating certification requirements for use of electronic health records, and seeking opportunities to waive patient cost-sharing.
    • Verify the accuracy of data collected during the initial data collection period under the Clinical Laboratory Fee Schedule before applying it to payment and, moving forward, notify applicable physician office laboratories in advance of the data collection period.
    • Finalize the proposed implementation delay of appropriate use criteria (AUC) and extend the education and testing year through at least 2019.
    • Hold clinicians harmless from 2018 penalties under the largely obsolete PQRS, Value-Based Payment Modifier (VM) and EHR Incentive Program (Meaningful Use) programs if they demonstrated a clear attempt to participate in these programs in 2016 by successfully reporting at least one measure.
    • Clarify eligibility requirements for furnishing care under the expanded Medicare Diabetes Prevention Program and allow physician group practices to furnish these services virtually.
    • Implement MGMA’s detailed recommendations in response to the Request for Information on CMS Flexibilities and Efficiencies to significantly decrease unnecessary regulatory paperwork and improve the quality and efficiency of healthcare delivery in this country.
    • Use the results of MGMA’s regulatory burdens survey as a tool to help provide regulatory relief for medical group practices (see attached).

     

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