October 2, 2020

The Alliance submitted comments and recommendations to CMS’s proposed CY2021 Physician Fee Schedule. Our comments:

  • Oppose cuts in  payment for surgical procedures and physical therapy services and urged the Agency to prevent drastic cuts from occurring while physicians are still trying to recover and gain their financial footing from the effects of the pandemic.
  • Urge CMS to not only accept the RUC recommendations for the values of E/M codes, as they have proposed, but to also apply these updated values to the global procedure codes. We flagged that implementing new values for E/M codes when billed independently - but not implementing those same values in the global packages - disrupts the relativity in the entire physician fee schedule and creates specialty differentials even when performing the same work.
  • Recommend that the Agency consider creating a MIPS Value Pathway (MVPs) for Chronic Wound Management and utilize the QCDR measures which already exist for wound care. 
  • Encourage CMS to maintain a patient’s home as an originating site even when the Public Health Emergency expires. 

See additional recommendations and suggestions to CMS in the full-text of Alliance comments, below.

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