AAFP Continues Dialogue With CMS

"Physicians are subject to a unique business model where a third party regulates not only their business model but also the payment for their services, and where the purchaser of the services is distanced from the costs," said AAFP Board Chair Larry Fields, M.D., of Flatwoods, Ky., in an Oct. 6 letter (PDF file: 8 pages / 59 KB. More about PDFs.) to CMS Administrator Mark McClellan, M.D., Ph.D.

The letter details AAFP's comments on CMS' proposed notice regarding Medicare's revisions to payment policies for the 2007 physician fee schedule and changes to payment under Part B that was published in the Aug. 22 Federal Register.

"Physicians are under tremendous pressure from both public and private sectors to lower costs and provide high quality care while receiving the same or less income and facing ever-rising costs of delivering care," said Fields.

In the letter, Fields took the opportunity to repeat the Academy's disagreement with CMS' proposed approach to budget neutrality. "We believe that CMS should implement any statutory budget neutrality adjustments through an adjustment to the conversion factor," said Fields. Doing so "reflects the nature of the budget neutrality adjustment which is made for fiscal reasons and not based upon a change in work values."

Fields also reiterated the Academy's support for the elimination of all geographic adjustment factors from the Medicare physician fee schedule except for those designed to achieve a specific public policy goal such as encouraging physicians to practice in an underserved area.

"We believe that reimbursement of physician services should not be based on the geographic location where the service is provided and that equivalent service should result in equivalent compensation," said Fields. He pointed out that CMS is proposing a negative-percent change in the geographic adjustment factor in states such as South Dakota, North Dakota, Missouri and Montana that already have regions designated as physician shortage areas. "This negative adjustment may further exacerbate the difficulty of recruiting physicians to these areas and limit access to care for Medicare beneficiaries in these areas," said Fields.

Fields encouraged CMS to make regulatory changes that protect the ability of legitimate small group practices to maintain laboratories and other ancillary services in a centralized building and to refrain from requiring the hiring of full-time non-physician employees to perform those ancillary services.

"I would encourage CMS to not take a broad stroke approach to addressing this perceived area of risk related to contracted physician services." said Fields. "Where legitimate small group practices find means to provide convenient and cost-effective care to patients, it is in no one's best interest to restrict these practices."

Acknowledging an issue on which the Academy and CMS are in agreement, Fields said if physicians are to be held responsible for inaccurate claims information, they must have unlimited access to those claims records for which they could be held liable. "The OIG (Office of Inspector General) has indicated that physicians will be held responsible for the accuracy of claims submitted in their names regardless of their knowledge of the claims," said Fields.

Fields said that while the Academy supports transparency in health care information, it would encourage CMS to consider how the information is presented and urged CMS to include education "on the complexity and lack of true quality indicators in the present health care system."

He reiterated the Academy's commitment to providing quality, cost-effective health care and pointed out AAFP's support of and participation in the Ambulatory Care Quality Alliance, or AQA.

Fields urged CMS to continue to look for ways to help physicians acquire interoperable electronic health record systems because doing so will help remove barriers associated with the reporting of clinical data.

Finally, Fields suggested that as CMS continues to develop a project to provide the public with comprehensive information on quality and costs, it should "consider the value of the resources to be spent on this project and whether some of these might be better spent in developing a public health system which assists physicians in the delivery of quality care through practice redesigns such as adoption of electronic health records, group medical visits and patient registries, and which encourages each patient to have a personal medical home through which their care is coordinated."