The American College of Physicians (ACP) responded on May 31 to a Senate Finance Committee (SFC) request for recommendations on how to improve the Medicare physician fee schedule and fee-for-service (FFS) system. A 20-page letter from ACP President Molly Cooke, MD, FACP, to SFC Chairman Max Baucus and Ranking Member Orrin Hatch cited ways to provide stability for physician reimbursement and lay the necessary foundation for a performance-based payment system following the repeal of the Sustainable Growth Rate (SGR) formula.
The letter provided 19 specific recommendations, supporting evidence and implementation details in addressing three main areas of inquiry from the SFC;
- What specific reforms should be made to the physician fee schedule to ensure that physician services are valued appropriately?
- What specific policies should be implemented that could coexist with the current FFS physician payment system and would identify and reduce unnecessary utilization to improve health and reduce Medicare spending growth?
- Within the context of the current FFS system, how can Medicare most effectively incentivize physician practices to undertake the structural, behavioral and other changes needed to participate in alternative payment models?
On relative values, ACP’s recommendations included:
- continue the work of the RVU Update Committee (RUC) to identify potentially over-valued services;
- direct the Centers for Medicare & Medicaid Services (CMS) to gather independent data to improve RVU accuracy;
- authorize CMS to pay physicians for the work that falls outside of a visit involved in care coordination; and
- redirect payments from overvalued procedures to undervalued evaluation and management services.
On utilization, ACP’s recommendations included:
- create an add-on to evaluation and management codes when physicians document that they have incorporated high-value care clinical guidelines (such as guidelines from ACP’s High Value Care Initiative) into their practices and engaged patients in shared decision-making based on such guidelines; http://hvc.acponline.org/index.html
- develop alternatives to pre-authorization that would encourage the use of appropriateness criteria by “outlier” practices;
- especially encourage use of such appropriateness criteria, and provide timely educational feedback, to physicians in practices that own ancillary services if they have higher utilization compared to peers that do not have such an ownership interest;
- expand bundled payments to more services and conditions; and
- explore ways to provide physicians with accurate data on the quality and total cost of care provided by other clinicians and hospitals within their geographic communities to enable them to make informed referral decisions.
On transitioning to new payment models, ACP proposed a detailed plan that would repeal the SGR, stabilize payments for five years, provide positive baseline payments to all physicians, and create a new value-based incentive update program that would provide higher updates, on graduated scale, to physicians who participate in programs to improve the quality and effectiveness of care, including Patient-Centered Medical Homes.
In her letter to Baucus and Hatch, Cooke stated, “We applaud you for your leadership in addressing the flawed SGR and for your initiative in working to advance a solution with input from physicians, physician organizations and other stakeholders. The College appreciates this opportunity to share its recommendations on how to improve the Medicare physician fee schedule and the FFS system overall to provide stability for physician reimbursement and lay the necessary foundation for a performance-based payment system following the repeal of the SGR.”