September 20, 2019: MGMA shares comprehensive comments on 2020 Medicare Physician Fee Schedule proposals

Advocacy Letter

Medicare Payment Policies

Quality Payment Program

September 20, 2019

The Honorable Seema Verma
Centers for Medicare & Medicaid Services
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201

RE: Medicare Program; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies and the Quality Payment Program

Dear Administrator Verma:

The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the proposed rule entitled, “Medicare Program; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies,” published on

August 14, 2019, with file code CMS–1715—P. MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, people, insights, and advocacy, MGMA empowers medical group practices to innovate and create meaningful change in healthcare. With a membership of more than 45,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 practices of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.
Key Recommendations

MGMA appreciates CMS’ leadership in improving Medicare and respectfully offers the following recommendations to assist CMS in achieving its goals of reducing clinician burden and improving patient care. In summary, we encourage the agency to:
  • Finalize the proposal to maintain separate payment rates for E/M visit levels for established patients and reduce the number of levels for new patients by deleting CPT code 99201. We appreciate CMS’ proposal to revise the previously finalized E/M payment changes and align them with the CPT/RUC recommendations.
Download the full letter

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