The Alliance of Specialty Medicine submitted comments on the 2020 Medicare Physician Fee Schedule proposed rule expressing concerns about a number of provisions that would negatively impact beneficiary access to specialty care. The Alliance urged CMS to translate the updated E/M values to global surgery codes given concerns about the precedent CMS is setting for future valuation of services, as well as the impact on the relativity of PFS services. The coalition also expressed appreciation for CMS’ proposal for Principal Care Management (PCM) services which emphasize the role of specialists in managing chronic health conditions within their domain. In addition, the 15 specialty groups provided feedback in response to CMS’ request for information on a proposed framework for a new pathway under the Quality Payment Program (QPP) – MVP, or Merit-Based Incentive Payment System Value Pathways. Despite the positive aspects, the framework alludes to mandatory participation, as well as the continued reliance on administrative claims-based measures, all without addressing the fundamental challenges facing clinicians under the current MIPS program. Read the Alliance comments to learn more.