The Alliance of Specialty Medicine submitted a thoughtful and detailed letter to CMS in response to the proposed rule on the Medicare Physician Fee Schedule.  

Among the many issues covered in the letter are:

 

1. Mis-valued Code Initiative: CMS is not considering the quality and value of the services, only the utility.

2. MACRA: It is critical that CMS maintain flexibility and recognize a wide range of quality improvement activities and alternative payment models that reflect the unique practice of specialists.

3. Payment Accuracy: As CMS proposes improvements to primary care and care management services, it needs to ensure these codes are not limited in their use to primary care specialties.

4. Appropriate Use Criteria: The Alliance strongly opposes the use of AUC to withhold payments.

5. Physician Compare: The Alliance has great concerns about CMS′ ambitious timeline to make physician quality and cost performance data available to the public.

Click here to access a copy of the letter.