APTA has joined with more than 150 other health care organizations to let the US Centers for Medicare and Medicaid Services (CMS) know that while its "Patients Over Paperwork" efforts are appreciated, one CMS attempt to reduce administrative burdens is likely to result in reduced access to care for some of the sickest Medicare beneficiaries.

The concerns center around a provision related to evaluation and management (E/M) visits included in the 2019 physician fee schedule rule proposed by CMS over the summer. The change, ostensibly intended to reduce paperwork, would collapse E/M payment rates currently based on a 5-level complexity system for new and established patients into what would amount to a 2-level system—combining levels 1-3 and levels 2-5. CMS acknowledges that the change would result in higher payments for E/M visits at the 1-3 levels while levels 4 and 5 will see reductions based on the 2019 proposed relative value units. However, CMS argues, the reduced paperwork burden would offset the payment drop.

In a letter sent to CMS last month, APTA and other cosigners praise CMS for its initiative to reduce provider paperwork, but question the wisdom of the E/M plan, arguing that the change would unfairly impact providers who see sicker patients, "ultimately jeopardizing patients' access to care."

The group also is pushing back against a related plan to reduce payment for multiple services delivered on the same day, something that they argue was already accounted for in previous valuations of the relevant codes.

As an alternative, the group urges CMS to collaborate with an American Medical Association-sponsored crossdisciplinary work group. That work group has been charged with analyzing E/M coding and developing a better alternative than the one presented by CMS. APTA will be monitoring the work of this group and participating in future meetings.