The Alliance of Specialty Medicine submitted detailed comments to CMS in response to a proposed rule on the CY 2018 Medicare Physician Fee Schedule. While the Alliance is encouraged by a number of proposals, including those that would eliminate penalties for many physician’s subject to now-sunset quality improvement programs, it remains concerned about the agency’s activities surrounding the potentially misvalued code initiative, how it intends to address updating malpractice relative values, and most importantly, continues to implement the appropriate use criteria for advance diagnostic imaging program. The Alliance also addresses other key issues of importance to specialists,including Evaluation and Management (E/M) guidelines, patient relationship categories and codes, and modifications to the Medicare Shared Savings Program (MSSP).
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