September, 2018

Dave Gilchrist, MD

We Expect Better!

The Center for Medicare Services (CMS) recently came out with the proposed 2019 Medicare Physician Fee Schedule and you could spend weeks reviewing the over 1,400 pages to try and understand this complex set of rules and regulations. The good news is that you don't and the AAFP has staff that does this on our behalf. Out of the review of this proposed physician fee schedule came one proposal that could effect how many of us bill and are paid. Under this proposed fee schedule is a proposal to collapse the Medicare payment for E/M codes (levels 2 -5) into a single payment amount. This would apply to both new and established pateients. Additionally, any service provided on the same day as an E/M service would have a 50% reduction in payment for that service. These changes could have a dramatic negative impact on the payment for members of Mass AFP and would likely lead to some unintended consequences. The collapsing of the E/M level 2 -5 into one flat payment would incentive more frequent and shorter visits. The 50% reduction in payment for services rendered on the same day through use of the 25 modifier would greatly reduce payments to doctor and has no clear positive benefit to our member, only negative consequences. While the proposal is meant to reduce the administrative burden by allowing doctors a flat fee for the same level of documentation, it is technically flawed at achieving this goal, and would only apply to Medicare patients. The AAFP has argued that reducing the administrative burden from documentation can be done without tying it to payment reform and the AAFP has offered an alternative to the proposed payment reforms through the Advanced Primary Care Alternative Payment Model (APC-APM).

CMS is looking for feedback on these proposed changes and the AAFP will be giving them feedback from members prior to the September 10 deadline. In addition, the AAFP has asked individual members to let your voices be heard during this period. If you have comments on AAFP's approach, or if you wish to share recommendations on how the AAFP should respond to the proposed rule, please email AAFP Senior Vice President of Advocacy, Practice Advancement and Policy Shawn Martin at with the subject line "MPFS2019."


Dave Gilchrist, MD