Proposed Medicare Physician Fee Schedule Does Little to Build Primary Medical Care Foundation

Friday, July 14, 2017

Statement attributable to:
John Meigs, Jr., MD
American Academy of Family Physicians

“With the release of the proposed 2018 Medicare Physician Fee Schedule, the AAFP appreciates that CMS included several AAFP-recommended administrative simplification provisions which, if finalized, will significantly reduce the burdens primary care practices currently experience when participating in the Medicare program.

“As the AAFP has discussed with the agency, this proposed rule shows that CMS recognizes that the Evaluation and Management (E/M) 1995 and 1997 documentation guidelines are too complex and ambiguous. By calling for comments on E/M documentation guidelines, CMS recognizes that these guidelines, which were written 20 years ago, do not reflect the current use of electronic health records and team-based care to support clinical decision-making and patient centeredness. The AAFP has called for changes in these outdated documentation guidelines and we look forward to providing our recommendations to CMS.

“We are also pleased that CMS has begun implementing site-neutral provisions to ‘new’ off-campus provider-based departments, policies the AAFP has supported in regulatory and legislative letters. Furthermore, we are pleased that CMS proposes to delay until Jan. 1, 2019, the Appropriate Use Criteria program for advanced diagnostic imaging services, which the AAFP repeatedly expressed concern over due to the disproportional administrative burden this would place on primary care physicians. We also appreciate that CMS lowered the maximum amount of risk under the 2018 value modifier program from 4.0 percent to 1.0 percent for practices of less than 10 physicians. Finally, CMS efforts to retroactively reduce the number of 2018 Physician Quality Reporting System measures to six is supportable since it further aligns the PQRS with the Merit-based Incentive Payment System’s quality measure reporting requirements.

“However, the AAFP is disappointed that CMS failed yet again to achieve the required, minimum net expenditure reduction through identifying misvalued codes. Since these changes do not fully meet the misvalued code target required by law, physicians will not receive the full positive 0.5 percent update in 2018 called for in the Medicare Access and CHIP Reauthorization Act. The proposed 2018 Medicare conversion factor will be $35.99, an increase of only $0.10 (0.31 percent) from the 2017 conversion factor.

“Reforming the physician payment system will unfold over time. As CMS moves to replace payment for individual procedures with payment for value and quality of care, we remind the agency that it’s important to strengthen the primary medical care that supports the system-wide reforms taking place today and for years to come.”

Editor's Note: To arrange an interview with Dr. Meigs, contact Megan Moriarty, 800-274-2237, Ext. 5223, or

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Founded in 1947, the AAFP represents 129,000 physicians and medical students nationwide. It is the only medical society devoted solely to primary care.

Family physicians conduct approximately one in five office visits -- that’s 192 million visits annually or 48 percent more than the next most visited medical specialty. Today, family physicians provide more care for America’s underserved and rural populations than any other medical specialty. Family medicine’s cornerstone is an ongoing, personal patient-physician relationship focused on integrated care.

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