In the formal communication, ASA and the other signatories noted their appreciation for CMS’s efforts to reduce administrative burdens for Evaluation and Management (E/M) services by offering alternatives to the current documentation requirements, but expressed opposition to the implementation of collapsed payment rates and a proposed multiple procedure payment reduction (MPPR). The organizations also encouraged CMS to support a joint CPT/RUC workgroup’s efforts to provide an alternative proposal to address payment, coding, and documentation issues for E/M services.
ASA will also submit its own comments to CMS addressing E/M and other issues in in the proposed rule covering both the Medicare Physician Fee Schedule and the Quality Payment Program (QPP).