•Further jeopardize physician practice sustainability, and
•Risk penalizing physicians unfairly.
🔥CMS’s policies increase
administrative demands on physicians.
🧵
2/ This week, @AmerMedicalAssn submitted a 122-page comment letter in response to the @CMSGov proposed rule for the 2024 #Medicare Physician Fee Schedule (PFS) and Quality Payment Program (QPP).
“Physician practices cannot continue to absorb increasing costs while their payment rates dwindle. We already know how that story ends, and it is not a happy ending” for patients.
4/ “According to the Medicare Trustees, if physician payment does not change, access to Medicare-participating physicians will become a significant issue in the long term.”
6/ “We appreciate that in the Consolidated Appropriations Act of 2023, Congress partially mitigated a 4.5 percent cut to Medicare physician payment rates,
but physicians still endured a two percent pay cut this year…
7/ …and for 2024, physicians are facing another 1.25 percent cut, once again confronting the grim task of reconciling how to keep their lights on while getting paid less, while their expenses continue to rise.”
❗️Cost of running a medical practice ⬆️ 4️⃣7️⃣% (1.8%/y)
❗️Physician payment rates have ⬆️ just 9️⃣% (0.4%/y), per Medicare Trustees.
❗️Adjusted for inflation, Medicare physician payment rates ⬇️ 2️⃣6️⃣% from 2001 to 2023, or by 1.3% /year.
9/ “Hospitals, skilled nursing facilities, and nearly every other Medicare provider receive an annual update.”
[Not physicians]
10/ “Physicians compete in the same marketplaces as these providers for clinical and administrative staff, equipment, and supplies.
Yet physicians are at a significant disadvantage due to payment cuts and because their payments have failed to keep up with inflation.”
11/ ❗️“It is no wonder that these trends are driving consolidation,
❗️which is highly likely to increase future Medicare costs
❗️as these other providers receive increasingly higher payments than
❗️the diminishing number of independent medical practices.”
12/ “This Administration has acknowledged that health care consolidation is leaving many areas, particularly rural communities, with inadequate or more expensive health care options.”
15/ In March, “the Medicare Payment Advisory Commission (MedPAC) recommended that Congress increase 2024 Medicare physician payments above current law by linking the payment update to the MEI, something the AMA and organized medicine have long supported.”
16/ “MedPAC raised concerns about the growing gap between what it costs to run a medical practice and what Medicare pays.”
17/ CMS is strongly urged:
🎇”Use every policy lever available to reduce the proposed budget neutrality reduction for physician services in 2024”
…CMS should ⬇️ utilization estimate for office visit add-on code, which would ⬇️ the budget neutrality cut to conversion factor.
18/ CMS is strongly urged:
🎇”Close the gap between the Medicare physician payment update and the rising cost of practicing medicine, which is estimated to increase by 4.5 percent next year.”
19/ AMA and Federation “strongly support H.R. 2474, the ‘Strengthening Medicare for Patients and Providers Act,’ which provides a permanent annual update equal to the increase in the MEI.”
21/ Enactment of an inflation-based update for physicians would “…enable CMS to prioritize advancing high-quality care for Medicare beneficiaries without the constant specter of market consolidation or inadequate access to care.”
22/ “These concerns stem from the disparity between Medicare physician payment rates and the actual costs associated with delivering high-quality care.”
23/ 🚩CMS must meaningfully reduce burden for MVP participants
“…CMS must make meaningful reductions in burdensome reporting requirements for MVP participants, and we offer…recommendations to do so:”
24/ CMS should:
🚩Develop MVPs by condition, episode of care and clinical priority areas, not by specialty; working work with national medical specialty societies
🚩Ensure MVPs and subgroup reporting remain voluntary
Don’t simply repackage problematic measures.
25/ 🚩Reduce substantial administrative burdens of MIPS
Physician practice leaders from a variety of specialties, practice types and locations reported that MIPS caused substantial administrative burden.
27/ “In a survey of 400 physician practices, 76 percent of respondents felt that MIPS is very or extremely burdensome, and 87 percent reported that MIPS payment adjustments do not cover the cost of time and resources needed for program participation.”
•Since there may not be a viable APM for every sub/specialty,
•Traditional MIPS should be permanently retained as an option for those clinicians.
•AMA continues to strongly oppose retiring traditional MIPS and making MVP participation mandatory.
29/ Precarious time for physician practices:
Compounding this financial distress with an expansion of MIPS penalties threatens the viability of physician practices & patient access to care.
⬇️ the performance threshold in 2024 or, at a minimum, maintain the 75-point threshold.
30/🚩Physician practice instability:
“While the AMA is calling on Congress to replace the statutory freeze with inflationary updates, CMS must avoid exacerbating the financial distress facing physicians with the proposed increased performance threshold.”
“The Government Accountability Office has highlighted these barriers [undue administrative burden and high costs of complying with MIPS] to participation for small and rural practices.”
Physicians caring for more medically/socially underserved, more likely to receive low scores despite high-quality care, penalized for social factors outside of their control
33/“CMS should not expand this flawed program to increasingly penalize physicians with [up to] 9% ⬇️ of Medicare payments, particularly on the heels of the COVID-19 PHE, when physicians must absorb highest practice costs in recent history despite lack of an inflationary update.”
34/ 🚩Remove Total Per Capita Cost Measure from MVPs
•Outdated measure specifications
•Significantly impact reliability and validity of the measures
•Lead to inaccurate measure results and unintended consequences for physicians and physician groups
Physicians should not be held responsible for costs that occurred long after they saw the patient.
The same costs should not be attributed to multiple physicians in different practices when there is no evidence that they are practicing as a team.
36/🚩Promoting Interoperability [PI] will 2️⃣❌ admin & EHR requirements:
Ignoring: “EHR burden also continues to ⬆️. Half of physician time is spent in EHR, 37% of physician/patient time is spent on nonclinical tasks, & physicians spend 2 hours of extra work outside the clinic.”
37/🚩Burnout and patient harm:
“Increasing EHR use may increase patient harm, rather than reduce it. It is a falsehood to believe that expanding physicians’ EHR demonstration requirements will reduce patient harm—CMS’s belief is neither backed by data nor evidence.”
38/ “AHRQ states that ‘burned-out doctors are more likely to leave practice, which reduces patients’ access to and continuity of care.’”
“Research also shows that MIPS can have a disproportionately negative association with certain practices, including those that are small, rural, independent, or serve a high proportion of patients with low-income.”
“The AMA’s 2022 Physician Practice Benchmark Survey shows that 71 percent of physicians cite regulatory and administrative requirements as their reason to leave independent medical practice.”
As state legislative sessions come to a close, AMA Scope of Practice Partnership (SOPP) grantees are reporting positive results. NY is among them, seeing overwhelming success in the face of over a dozen scope of practice bills. 👏👏
2/ Since its inception in 2007, the SOPP has awarded over $3.5 million in grants to medical societies funding initiatives to:
• Fight inappropriate scope of practice expansions,
•Promote truth in advertising and
•Protect physician-led care.
#transparency #accountability
3/ The SOPP is a collaborative effort staffed by the AMA and comprised of the @AmerMedicalAssn, the @AOAforDOs, 18 national specialty societies, 50 state medical associations and 39 state osteopathic medical associations.
🧵CMS proposed rule widens chasm between Medicare physician payment and cost to keep the lights on.
❗️Patients’ access to care is at risk.
❗️Should be a wake up call to #Congress to reform the #Medicare physician payment system.
2/ As @AmerMedicalAssn staff analyze and develop a summary of the nearly 2,000-page rule, they flag a few key provisions and concerns.
Notably:
“Physician practices cannot continue to absorb these increasing costs while their payment rates dwindle.“
3/ “This is why the AMA and our partners in organized medicine strongly support H.R. 2474…which would provide a permanent, annual update equal to the increase in the MEI and allow physicians to invest in their practices and implement new strategies to provide high-value care.”
🧵@AmerMedicalAssn & Federation letter to @Cigna expresses opposition to its forthcoming policy that will require submission of office notes with all claims including evaluation & management services & modifier 25 when a minor procedure is billed.
Read the letter here👇
2/ >100 state medical associations & national medical specialties
“…request that Cigna immediately rescind its policy requiring submission of office notes with all claims including…E/M…CPT codes 99212, 99213, 99214, & 99215 & modifier 25 when a minor procedure is billed.”
👇
3/ “We urge Cigna to reconsider this policy due to its negative impact on practice administrative costs and burdens across medical specialties and geographic regions, as well as its potential negative effect on patients, and…”
🧵”The approval process health insurers impose on medical services or drugs is generating a toll that exceeds the purported benefits, according to a physician survey released today by @AmerMedicalAssn and shared in a letter to federal health officials.”
2/ For an infographic of the survey results, please see👇
3/ “While health insurers claim prior authorization requirements are used for cost and quality control, a vast majority of physicians say authorization controls lead to unnecessary waste and avoidable patient harm.”
2/ “The 340B program was established in response to concerns among safety-net providers regarding the Medicaid Drug Rebate Program, which was enacted in 1990 and required manufacturers to offer their lowest prices to the Medicaid program.”
3/ “An inadvertent effect of [Medicaid Drug Rebate] policy was that safety-net providers lost access to the discounts they had previously received from drug manufacturers. The 340B program was intended to restore discounts to providers caring for low-income and uninsured people.”
“The AMA already has serious concerns about #PBM business practices that can have a detrimental impact on patients’ access to and cost of prescription drugs.”