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:
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.