“While we are encouraged by CMS’ continued focus on reducing physician paperwork burden, we are deeply concerned that the proposed cuts to cognitive evaluation and management (E/M) services, along with the methodology changes to practice expense (PE), will further restrict patient access to rheumatologists and other cognitive specialists at a time when the workforce is already shrinking. E/M services by rheumatologists are critical for effectively managing and reducing the long term functional and economic costs of many debilitating diseases. These proposed cuts will have significant negative impacts on rheumatology practices.

The cuts also go against the recommendations of MedPAC, which earlier this year proposed increasing reimbursement for E/M services given the time and intensity they require, and noted that E/M services are already undervalued relative to other physician services. There is also the risk that additional cuts would worsen the current rheumatology workforce shortage and add additional strain on patients’ ability to access rheumatology care.

Further, we are concerned that the proposal to reduce Medicare Part B reimbursement for new drugs to Wholesale Acquisition Cost (WAC) plus 3 percent could slow market uptake of biosimilars and thwart the Administration’s efforts to reduce drug prices.

Regarding this year’s Quality Payment Program Proposed Rule, we appreciate CMS’ emphasis on supporting the development of alternative payment models (APMs) and are encouraged by the agency’s proposal to allow more physicians to participate. However, we are concerned that eliminating the MIPS small practice bonus as a stand-alone bonus and instead folding it into the quality performance score would dilute the bonus and hurt small and rural providers. The ACR strongly supports maintaining the small practice bonus as a 5 point stand-alone bonus that is added to the final score.

We will submit detailed comments in the coming weeks and look forward to continued dialogue with CMS about the proposed changes.”

# # #

About the American College of Rheumatology

The American College of Rheumatology (ACR) is the nation’s leading advocacy organization for the rheumatology care community, representing more than 7,700 U.S. rheumatologists and rheumatology health professionals. As an ethically driven, professional membership organization committed to improving healthcare for Americans living with rheumatic diseases, the ACR advocates for high-quality, high-value policies and reforms that will ensure safe, effective, affordable and accessible rheumatology care.