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AAAAI News on Physician Payment Policy

April 22, 2024
The American Medical Association published its updated specialty impact analysis. This table shows the effect of both 2024 conversion factors and their estimated impact on payment across medical specialties.

March 21, 2024
CMS Updates CY 2024 Medicare PFS Conversion Factor
The Centers for Medicare and Medicaid Services (CMS) recently posted the new CY 2024 Medicare Physician Fee Schedule (PFS) conversion factor, now set at $33.29, following enactment of the Consolidated Appropriations Act, 2024. The newly updated CY 2024 CF is effective March 9, 2024 through December 31, 2024, and is reflected in CMS’ payment files, including its RVU tables. Additional details can be found on CMS’ website.

January 17, 2024
The AAAAI, the American Medical Association and others continue to actively advocate for immediate Congressional action to reverse the 3.37 percent Medicare physician payment cuts that took effect on January 1, 2024. Read the letter joined by the AAAAI and many others.  To support the campaign, visit

December 14, 2023
The AAAAI and other organizations have been working to reduce damage to patient access to care caused by cuts in physician reimbursement in the 2024 Medicare Physician Fee Schedule. Our expert government relations consultants at Hart Health Strategies have prepared this chart comparing related legislation.

November 13, 2023
Our expert government relations consultants at Hart Health Strategies have prepared analyses of the Centers for Medicare and Medicaid Services (CMS) 2024 Medicare Physician Fee Schedule.

•  The Calendar Year (CY) 2024 Medicare Physician Fee Schedule Payment and Quality Programs and Policy Provisions provide side-by-side comparisons of the proposed and final.
Updated payments for select A/I codes are available here.

Of note, the final CY 2024 MPFS conversion factor is set at $32.7442, which is down approximately 3.4 percent from CY 2023. The reduction is the result of several factors, including the statutory base payment update of 0.00 percent, the reduction in assistance provided by the Consolidated Appropriations Act, 2023 (CAA, 2023; from 2.5 percent for 2023 to 1.25 percent for 2024), and budget neutrality adjustments of -2.18 percent resulting from CMS’ finalized policies (p. 1948).

For quick reference, CMS’ Specialty Impact Table (Table 118) includes estimated impacts in Medicare payments to specialties based on the policies outlined in the final rule (which does not include the reduction in assistance under the CAA, 2023). CMS also provided an additional impact table, Table 119, that includes a facility/non-facility breakout of payment changes.  
You can review the American Medical Association summary of 2024 Physician Payment Schedule (MFS) Final Rule here.
Additional links:
•    CMS Press Release
•    CMS Fact Sheet on the 2024 Medicare Physician Payment Schedule final rule  
•    CMS Fact Sheet on 2024 Quality Payment Program final changes
•    CMS Fact Sheet on Medicare Shared Savings Program final changes

November 2, 2023
The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2024 Medicare Physician Fee Schedule (MPFS) final rule. The CY 2024 MPFS conversion factor is $32.7442 – a decrease of approximately 3.37% ($1.15) from the CY 2023 MPFS conversion factor of $33.89. Our professional government relations consultants at Hart Health Strategies are currently drafting an analysis to highlight its impacts on the Allergy Immunology specialty.

Review adjustments in reimbursement for the Allergy Immunology specialty.

September 11, 2023
AAAAI asked the Centers for Medicare and Medicaid Services (CMS) to work with Congress to address ongoing reductions to the Medicare physician fee schedule (PFS) conversion factor, and to establish a more consistent and regular approach for direct and indirect Practice Expenses. AAAAI further asked CMS to exempt the complexity add-on code from budget-neutral adjustments and provide clear coding and billing guidance and retain active payment status to telemedicine E/M services, among other measures. CMS anticipates a conversion factor of $32,7476 for Calendar Year (CY) 2024. Read our letter.

The AAAAI and others have urged the Centers for Medicare and Medicaid Services (CMS) to ensure Medicare beneficiaries have access to the medications they need, in the lowest cost, highest quality, and safest setting – the physician’s office. Read the letter.

August 1, 2023
The Centers for Medicare and Medicaid Services (CMS) released its fiscal year (FY) 2024 Inpatient Prospective Payment System (IPPS) final rule, which is effective beginning October 1, 2023. The final rule revises the Medicare hospital inpatient prospective payment systems (IPPS) for operating and capital-related costs of acute care hospitals; and makes changes relating to Medicare graduate medical education (GME) for teaching hospitals, among other policy-related changes. Hart Health Strategies, Inc. our professional government relations consultants, has prepared this “side-by-side” comparison of the proposed and final provisions, to better understand how CMS modified its proposals in response to stakeholder feedback.

July 13, 2023
The Centers for Medicare and Medicaid Services (CMS) released its calendar year (CY) 2024 Medicare Physician Fee Schedule (PFS) proposed rule on July 13, 2023. As is customary, CMS proposes key changes to the physician fee schedule (PFS) and other Medicare Part B payment policies. CMS estimates the CY 2024 PFS conversion factor (CF) to be $32.7476 - a downward adjustment of approximately .31 cents from the CY 2023 PFS CF of $33.0607. Projections also indicate a 1% downward adjustment for allergy / immunology services. The proposed reimbursement value reflects a budget neutrality adjustment of -2.17 percent, the 0.0 percent update adjustment factor required under the Medicare Access and CHIP Reauthorization Act (MACRA), and a +1.25 percent payment update provided under the Consolidation Appropriations Act, 2023.  Actual specialty impacts at the physician level will vary based on multiple factors, including practice size and services lines. Reimbursement for allergy / immunology services delivered in a facility setting is projected to increase by 2%.

Read a summary of Payment and Other Policy Revisions and a summary of Quality Improvement Programs and Other Alternative Payment Model Provisions provided by our expert government consultants at Hart Health Strategies. Read the American Medical Association (AMA) summary of the proposed rule here.

The AAAAI with Hart Health Strategies consultants will submit comments to CMS by September 11 in response to these proposals. 

April 19, 2023
HR 2474 Strengthening Medicare Patients and Providers Act would provide inflation adjustment for physician pay for Medicare
Legislation introduced on April 4 by a bipartisan group of physician members seeks to stabilize Medicare physician payment by providing an annual inflationary update equal to the Medicare Economic Index (MEI). The AAAAI joined many physician specialty societies and state medical associations in sending a letter led by the American Medical Association (AMA) in support of the bill. We will keep you informed on this very important issue for physician payment.

December 29, 2022
President Biden signed into law the $1.7 trillion Consolidated Appropriation Act of 2023 on December 29, 2022. The package, which funds the federal government through September 2023, reduces but does not eliminate Medicare physician reimbursement cuts. It extends telehealth flexibilities through December 31, 2024, and includes $12.1 million for the Consortium of Food Allergy Research (CoFAR) to expand its clinical research network. Click here to review additional key takeaways for Allergy/Immunology.

December 12, 2022
Urge Congress to Stop the Cuts.

November 9, 2022
Our expert government relations consultants at Hart Health Strategies have prepared the following analysis documents on the 2023 Medicare Physician Fee Schedule:

• This Payment and Other Policy Provisions Executive Summary includes Rebasing and Revising the Medicare Economic Index (MEI); geographic practice cost indices (GPCIs); Determination of Practice Expense (PE) RVUs; Valuation of Specific Codes; E/M Services; Medicare Telehealth Services and more.

• This Quality Payment Executive Summary covers the Quality Payment Program and Medicare Shared Savings Program (SSP).

• These side-by-side comparisons of the proposed and final rule for the CY 2023 Medicare Physician Fee Schedule Payment and other Quality Programs and Policy Provisions offer more in-depth analysis. 

November 1, 2022
The Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) final rule. The CY 2023 MPFS conversion factor is $33.0607 (or about 4.47% less than the CY 2022 MPFS conversion factor). Our professional government relations consultants at Hart Health Strategies are currently drafting an analysis to highlight its impacts on the Allergy Immunology specialty.

Review adjustments in reimbursement for the Allergy Immunology specialty.

October 31, 2022
The AAAAI submitted comments to a group of bipartisan members in the U.S. House of Representatives in response to a request for information seeking stakeholder feedback on actions Congress should take to stabilize the Medicare payment system. The letter to Representatives Bera, Bucshon, Schrier, Burgess, Blumenauer, Wenstrup, Schneider, and Miller-Meeks expressed deep concern about the ongoing reductions in payments to physicians under the Medicare Physician Fee Schedule, which created an increasingly unsustainable environment for A/I physician practices.

October 25, 2022
Medicare payment policy has a significant influence on how, and how much, physicians are paid for all patient services. But do you know how Medicare payment policy works? You can review the mechanics of the MPFS, how payment rates are calculated and what this means for your bottom line in this one-hour webinar, “Medicare Physician Payment, Where We’ve Been, Where We’re Headed.” Review the slides.

September 6, 2022
AAAAI asks CMS to work with Congress to change physician reimbursement policy

The AAAAI has raised serious concerns to CMS regarding the 2023 Proposed Physician Fee Schedule, asking that they “work with Congress on a long-term solution to the broken Medicare physician payment system,” emphasizing that “it will be impossible to modernize and reform our health care system, to include reducing health disparities” absent this action. The Academy also called on CMS to “pause consideration of other sources of cost data for use in the Medicare Economic Index until the efforts by the American Medical Association to collect practice cost data from physician offices is complete,” and to establish a more consistent and regular approach for collecting direct and indirect practice expense data. Additional issues addressed include telehealth, discarded drug rebates, and topics under the Quality Payment Program. Read our letter.

August 4, 2022
AAAAI joins coalition seeking Congressional fix to CY23 fee schedule proposal

The AAAAI joined other organizations representing more than one million physician and non-physician healthcare professionals asking Congress to do something about impending reimbursement cuts in the CMS 2023 Medicare Physician Fee Schedule in a letter. We will continue to keep you posted on a range of advocacy activities on this extremely important issue. 

July 21, 2022
CY 2023 Physician Fee Schedule proposed rule proposals raise concern for Allergy / Immunology

On July 7, the Centers for Medicare and Medicaid Services (CMS) released its CY 2023 Medicare Physician Fee Schedule (PFS) proposed rule, providing payment and policy changes for CY 2023. The proposed CY 2023 conversion factor is $33.0775, a -4.42% reduction in reimbursement rates, stemming from the 0.00% payment update prescribed under the Medicare Access and CHIP Reauthorization Act (MACRA), a budget neutrality adjustment of 1.55%, and the expiration of the one-time 3% payment update provided by Congress by way of the Protecting Medicare and American Farmers from Sequester Cuts Act for CY 2022.

The fee schedule also proposes changes to payment rate calculations, including rebasing/revising the Medicare Economic Index (MEI) and updating the Geographic Practice Cost Indices (GPCIs). CMS is delaying implementation of these of these proposals to allow input from stakeholders who may be impacted by these policies. Consistent with Consolidated Appropriations Act requirements, CMS also extends for 151 days after the end of the COVID-19 PHE provisions to extend certain telehealth services on the Medicare Telehealth List, and seeks feedback on whether to continue allowing virtual presence for direct supervision, at least for a subset of services. Read a summary of the payment provisions provided by our expert government consultants at Hart Health Strategies here

Read the American Medical Association summary of the Medicare Physician Fee Schedule Proposed Rule.

December 16, 2021
The Centers for Medicare and Medicaid Services (CMS) has announced an updated 2022 physician fee schedule conversion factor of $34.6062, equal to a 0.82% cut from its 2021 conversion factor of $34.8931. The revised value reflects an increase from the initial 2022 conversion factor of $33.5983 announced in the 2022 Medicare physician fee schedule final rule. Review new values for commonly used allergy/immunology codes.

September 2, 2021
The AAAAI is sending a letter to the Centers for Medicare and Medicaid Services (CMS) regarding proposed Calendar Year 2022 Payment Policies Under the Physician Fee Schedule and other proposed regulations on behalf of its members. AAAAI comments emphasize the impact on physician payment and the proposed conversion factor, clinical labor pricing, telehealth and virtual care, MIPS Value Pathways (MVPs), Qualified Clinical Data Registry (QCDR) Policies, and other issues, including concerns raised by members of the AAAAI Committee on the Underserved. Read more here.

July 26, 2021
Hart Health Strategies, the AAAAI’s expert government relations consulting team, has provided extensive summaries of the CMS 2022 proposed fee schedule. Reflecting the rule itself, the summary is divided into parts: one focuses on payment and other policy provisions; the other focuses on the quality programs and alternative payment models. Please also see this list of items from the rule that are of particular interest to the allergy / immunology specialty.

The AAAAI will be preparing comments to provide feedback on a range of the proposed changes. The final rule is expected to be published on November 1.

July 23, 2021
The AAAAI has urged with others that Congress and the Administration make a critical investment in the nation’s health care delivery system by maintaining its 3.75% increase to the conversion factor through at least calendar years 2022 and 2023. Read the letter.

July 13, 2021
The Centers for Medicare and Medicaid Services (CMS) released its CY 2022 Medicare Physician Fee Schedule (PFS) proposed rule. As is customary, CMS makes changes to the physician fee schedule (PFS) and other Medicare Part B payment policies. In addition, CMS updates the Quality Payment Program and makes changes to Medicare Shared Savings Program requirements. CMS also updates certain Medicare provider enrollment policies, makes requirements for pre-payment and post-payment medical review activities and for electronic prescribing for controlled substances for a covered Part D drug under a prescription drug plan, or a Medicare Advantage Prescription Drug (MA-PD) plan. CMS estimates the CY 2022 PFS CF to be $33.5848, a drop from the current (CY 2021) CF of $34.8931.

February 1, 2021

The AAAAI submitted comments on the CY 2021 Medicare Physician Fee Schedule (MPFS) Final Rule, including its interim final policies on Coding and Payment for Virtual Check-in Services and for Personal Protective Equipment (PPE) (CPT code 99072). Read more.

January 14, 2021
On January 14, 2021, the Centers for Medicare and Medicaid Services (CMS) released a fact sheet, Physician Fee Schedule (PFS) Payment for Office/Outpatient Evaluation and Management (E/M) Visits that provides additional information and guidance on recent changes to E/M services as a result of the CY 2021 PFS final rule.

Complex Care Add-on Code
In the CY 2021 PFS, CMS finalized an “add-on” code for visit complexity, HCPCS G2211. However, payment for the code was delayed under the Consolidated Appropriations Act, 2021, until January 1, 2024 or later. According to the CMS notice, “Practitioners may report this code for qualifying visits furnished on or after January 1, 2021, although we assigned a PFS payment status indicator of ‘B’ (Bundled) until 2024.”

Implementation of this add-on codes is anticipated to increase reimbursement for Allergy/Immunology professionals and other cognitive specialties. Therefore, we encourage AAAAI members to report this code with their E/M services (i.e., CPT 99202 – 99215). This will help CMS understand how the code would be used, as well as revise its budget neutrality estimates when the code is able to be reimbursed in CY 2024.   

Medical Review of E/M
CMS also discusses medical review when practitioners use time to select visit level, stating that, “Our reviewers will use the medical record documentation to objectively determine the medical necessity of the visit and accuracy of the documentation of the time spent (whether documented via a start/stop time or documentation of total time) if time is relied upon to support the E/M visit.”

It is necessary to appropriately document time in the medical record when it is used for E/M code selection. This may be supported through available audit tools as part of an electronic health record (EHR).

December 1, 2020
The Centers for Medicare and Medicaid Services (CMS) released its final CY 2021 Medicare physician fee schedule (PFS) rule, which includes changes to Medicare Part B payment policies, including payment for office/outpatient evaluation and management services, and the Quality Payment Program. CMS finalized its proposed essential changes for coding office visits and other related evaluation and management (E/M) services, including the G2211 code for complex visits, to be fully implemented as planned on January 1, 2021.

CMS estimates an 9% increase in allergy/immunology reimbursement, reflecting ongoing AAAAI advocacy work with the Cognitive Specialties Coalition and others on the E&M codes and increases in RVU values of key allergy/immunology codes. To compare 2021 reimbursement for allergy and asthma codes with 2020 reimbursement values. Compare 2021 reimbursement for Evaluation and Management (E/M). Review how reimbursement is calculated.

November 20, 2020
The AAAAI has joined with many others to urge that the 116th Congress implement essential changes in Medicare payments for office visits and other related evaluation and management (E/M) services, including the GPC1X code for complex visits, as planned and scheduled on January 1, 2021. Read the letter.

October 20, 2020
In coalition with others, the AAAAI urged Congress to:
• Move forward with fully implementing the increased payment for outpatient evaluation and management services and other improvements in the 2021 proposed and previously finalized Medicare Physician Fee Schedules,  including:
      o    Increased Valuation and Payments for Outpatient Evaluation and Management (E/M) Services
      o    Proposed new billing code, known as the GPC1X code, which would provide increased payment for complex care inherent to some of the office visit codes
• Ensure that any proposed legislation to address the cuts for some services resulting from budget neutrality (BN) is fair to all services and specialties, does not distort relative values and actual payments as determined through the usual regulatory process with public comment and input from physicians, and does not disadvantage primary and comprehensive care services compared to other services.
      o    Avoid temporary legislative fix that would create a future “funding cliff.” The following approaches could achieve such an outcome.

Read more.

October 1, 2020
The AAAAI and our professional governmental relations team, Hart Health Strategies, carefully reviewed the Centers for Medicare and Medicaid Services (CMS) proposed CY 2021 Medicare Physician Fee Schedule (PFS) and commented by letter to vigorously advance the practice of allergy, asthma and immunology for optimal patient care. Specifically, the AAAAI:

  • Urged CMS to work with Congress to eliminate the negative impact, concurrent with prompt implementation of the aforementioned E/M policies.
  • Urged CMS to proceed with implementation of the complexity add-on code, GPC1X.
  • Urged CMS to make Telehealth and Virtual Care Services flexibilities permanent.
  • Urged CMS to make audio-only E/M visits a permanent fixture in Medicare’s growing set of virtual care services codes, maintaining equal payment with in-person E/M visits.  

In response to updates to its Quality Payment Program, the AAAAI

  • Urged CMS to finalize the addition of multiple measures to the A/I Specialty Set for 2021
  • Opposed the CMS proposal to increase the overall MIPS performance threshold in 2021

August 20, 2020
The Centers for Medicare and Medicaid Services (CMS) released its CY 2021 Medicare Physician Fee Schedule (PFS) proposed rule August 3, 2020. As is customary, CMS makes changes to Medicare Part B payment and other policies to ensure that payment systems are updated to reflect changes in medical practice, relative value of services, and changes in the statute. CMS also makes changes to several other programs, including the Medicare Shared Savings Program (MSSP) and the Quality Payment Program (QPP). Of significance, and largely due to changes in RVUs for evaluation and management (E/M) services, CMS estimates the CY 2021 PFS conversion factor to be $32.2605, representing an almost -11% reduction from the CY 2020 conversion factor.

Click here for highlights impacting the Allergy Immunology specialty, and here to access a comprehensive summary prepared by the AAAAI's professional governmental relations team, Hart Health Strategies. See here for a brief summary from the American Medical Association. If you want to see the full posting, you can do so here.

2019 Physician Fee Schedule High Level Summary
Payment and Other Policy Changes
Conversion Factor: The CY 2019 PFS conversion factor is 36.0391, a +0.11 percent increase over CY 2018.
Valuation of Specific Codes: CMS finalized work RVUs and practice expense refinements for new, revised and potentially misvalued codes for CY 2019. Some of these codes will be of interest to you. The list begins on page 21 of our summary.
Direct PE Inputs: Market-based Supply and Equipment Pricing Update. CMS hired a contractor to gather and analyze new data for updating its supply and equipment pricing to refine direct PE inputs. In addition to make a number of proposals related to how CMS plans to incorporate this new data, CMS requested specific input on two allergy/immunology codes because of the disproportionate impact it has on the codes (even if CMS was to phase in the data). In particular CMS requested input on the direct PE pricing for:
     o    CPT 95165 (Professional services for the supervision of preparation and provision of antigens for allergen immunotherapy; single or multiple antigens (specify number of doses))
     o    CPT 95004 (Percutaneous tests (scratch, puncture, prick) with allergenic extracts, immediate type reaction, including test interpretation and report by a physician, specify number of tests)

CMS finalized the use of the data (and the 4 year phase in) but did not directly address any comments received about CPT 95165 or CPT 95004.

•  E/M Visits. CMS proposed a series of changes to E/M claims and documentation. CMS finalized some of its documentation proposals, delayed some of the payment proposals, and abandoned several of their related proposals altogether. CMS estimates that the impact of the cumulative finalized polices (once completely implemented, which is not slated until 2021) on allergy/immunology will, on the whole, be neutral (which is an improvement from the expected cut generated by the original proposals). Notable in the final rule:
     o    CMS modified its proposed policy to collapse office/outpatient E/M visit Levels 2 – 5 into a single payment level to doing so just for Levels 2 – 4 in CY 2021; physicians would still submit claims for visit levels 2-4, but because 2-4 receive the same payment level, only documentation needed to obtain a Level 2 is required (when documenting by current guidelines of MDM only.
     o    As proposed, CMS finalized that physicians will be able to choose whether to document via the existing 1995 or 1997 guidelines OR just medical decision making OR just by time (although this was also delayed to CY 2021).
     o    CMS finalized its proposal that for new and established patients, practitioners would no longer be required to re-enter information in the medical record regarding the chief complaint and history already entered by ancillary staff or the beneficiary (effective January 1, 2019).
     o    CMS did not finalize its proposal to apply the Multiple Procedure Payment Reduction (MPPR) policy to E/M visits billed on the same day as a global procedure.
     o    CMS finalized two level 2-4 E/M add-on codes: one for primary care and one for “non-procedural specialized care” (defined by a list of clinical areas which includes allergy/immunology).
     o    CMS finalized a modified version of its proposed new prolonged services E/M code (now referred to as an Extended Visit Service add-on code)

Changes to Teaching Physician Documentation for E/M Services. Under current billing rules, for procedural services, the participation of the teaching physician can be demonstrated by the notes in the medical records made by a physician, resident, or nurse. However, for E/M visits, the teaching physician is required to “personally document their participation in the medical record.” CMS finalized its proposal to eliminate the requirement teaching physician to personally be the one to document his/her presence and participation. CMS finalized that that the medical record must just document that the teaching physician was present at the time the service is furnished and that the note can be included by the physician, nurse, or resident.
Telehealth Services (and “Communication-Based Technology Services”). In addition to the typical discussion about potentially adding codes to the list of telehealth services, in the proposed rule, CMS made a major statutory interpretation change by essentially stating that the statutory restrictions on telehealth services should only be applied “to a discrete set of physicians’ services that ordinarily involve, and are defined, coded, and paid for as if they were furnished during an in-person encounter between a patient and a health care professional.” Thus, CMS proposed a series of “communication technology-based services” for separate payment (e.g. virtual check-ins and interprofessional consultations) since they were never intended to be face-to-face patient interactions anyway and therefore are not governed by the statutory restrictions on what Medicare can pay for as telehealth. CMS finalized payment for these services.
Price Transparency. In the proposed rule, CMS reiterated the language it has placed in several recent rules regarding price transparency and how it hopes to better relay cost information to beneficiaries in a way that patients find meaningful. CMS continues to be concerned about surprise billing for out-of-network services. In the final rule, CMS simply stated that it received 94 comments on the topic and thanks commenters for their input.
Part B Drugs: CMS finalized that effective January 1, 2019, WAC based payments for Part B drugs utilize a 3 percent add-on in place of the 6 percent add-on, consistent with MedPAC’s recommendation.

Quality Payment Program (QPP)
A detailed list of the QPP changes finalized for 2019 is available through this CMS fact sheet. Additional specific topics that might be of particular interest to your organization are highlighted below.

• General:
     o    CMS finalized 2019 performance category weights as proposed:
             o    Quality: 45%
             o    Cost: 15%
             o    Promoting Interoperability: 25%
             o    Improvement Activities: 15%
     o    CMS finalized a performance threshold of 30 points, and an exceptional performance threshold of 75 points for the 2019 period.
     o    CMS finalized a small practice bonus of 6 bonus points added to the quality performance category numerator.
• Quality
     o    Appendix 1, Table Group A: New MIPS quality measures finalized for inclusion in MIPS for the 2019 performance period and future years
     o    Appendix 1, Table Group B: Finalized new and modified quality measure specialty sets.
     o    Appendix 1, Table Group C: Measures finalized for removal for 2019.   
     o    Appendix 1, Table Group D: Quality measures with finalized substantive changes for 2019.
• Cost
     o    For 2019, CMS finalized the use of the Medicare Spending Per Beneficiary (MSPB) measure, the Total Per Capita Cost (TPCC) measure and 8 Episode-Based cost measures, which are listed in Table 36.
• Improvement Activities
     o    Appendix 2: Table A: New Improvement Activities for 2019
     o    Appendix 2: Table B:  Changes to previously approved Improvement Activities  
• CMS finalized multiple proposed policies related to QCDRs that would take effect in 2020, including:
     o    An updated definition to ensure QCDRs have clinical expertise in medicine and quality measure development
     o    A requirement that the QCDR must have at least 25 participants by January 1 of the year prior to the performance period
     o    A longer, but earlier QCDR self-nomination period (July 1-Sept. 1, rather than the current Sept. 1-Nov 1).  
     o    Applying select criteria used under the Call for Measures Process when considering QCDRs
             o    CMS is also considering proposing to require reliability and feasibility testing as an added criteria in order for a QCDR measure to be considered for MIPS in future rulemaking
     o    CMS did NOT finalize, at this time, its proposal to require QCDR measure owners to agree to enter into a license agreement with CMS permitting any approved QCDR to submit data on the QCDR measure for purposes of MIPS. Rather, it is retaining its existing policy that QCDR vendors may seek permission from another QCDR to use an existing measure that is owned by the other QCDR.
     o    Note that CMS is requesting additional feedback on multiple issues in this section.  

Advanced APMs & PTAC. In addition to finalizing most of the Other Payer Advanced APM proposals, CMS received comments that it should accelerate the availability of models and that there continues to be a lack of opportunities for specialists and non-physician. In reply, CMS cited increasing opportunities to participate in Advanced APMs, including in the BPCI Advanced model, the Maryland Total Cost of Care program, and stated that they are also “in the process of developing several new APMs and Advanced APMs, and continue to work with stakeholders on new models.” Stakeholders also expressed concern at the lake of uptake at CMMI of models recommended by PTAC. CMS stated that it understands the value of PTAC, noted that “while it seems unlikely that all of the features of any PTAC-reviewed proposed model will be tested exactly as presented in the proposal, certain features of proposed models may be incorporated into new or existing models.” Finally, the agency declined to accept a recommendation that the Secretary must reply to PTAC recommendations within 60-days (or any deadline).

QPP 2017 Performance and 2019 Impacts
• For the 2017 performance period, the mean score was 74.01 points and the median score was 88.97 points.
• CMS estimates that between 165,000 and 220,000 eligible clinicians would become QPs based on 2019 performance, qualifying for aggregate total APM incentive payments of approximately $600 million to $800 million for the 2021 payment year.
• CMS estimates that 97.8 percent of MIPS eligible clinicians will participate in MIPS, and of those, 91.2 percent are expected to receive positive or neutral payment adjustments.  
• CMS declined to provide estimates regarding QPP participation by specialty.

Appropriate Use Criteria (AUC)
• Expands the definition of an applicable setting to include independent diagnostic testing facilities;
• Creates significant hardship exceptions from the AUC requirements that are specific to the AUC program and independent of other Medicare programs;
• Establishes the coding methods, to include G-codes and modifiers, to report the required AUC information on Medicare claims; and
• Allows non-physicians, under the direction of an ordering professional, to consult with AUC when the consultation is not performed personally by the ordering professional.
• Clarifies that the AUC consultation information must be reported on all claims for an applicable imaging service (e.g., if separate, both the technical and professional claim must include the AUC information).

Medicare Shared Savings Program (MSSP)
• To reduce burden, CMS finalized its proposal to eliminate 9 measures and to add 2 measures to the Shared Savings Program quality measure set. The net result of the final policies included in this final rule is a set of 23 measures on which ACOs’ quality performance will be assessed for performance years during 2019 and subsequent performance years (compared to 31 measures used in 2018)
•  In a separate section of this rule, CMS also addresses a subset of changes to the Medicare Shared Savings Program (MSSP) for ACOs proposed in the August 2018 proposed rule “Medicare Program; Medicare Shared Savings Program; Accountable Care Organizations Pathways to Success” (see fact sheet) and addresses various other revisions designed to update program policies under the MSSP. In order to ensure continuity of participation and finalize time-sensitive program policy changes for currently participating ACOs, CMS finalized these and other policies:
     o    A voluntary 6-month extension for existing ACOs whose participation agreements expire on December 31, 2018, and the methodology for determining financial and quality performance for this 6-month performance year from January 1, 2019, through June 30, 2019.
     o    Promoting interoperability among ACO providers by adding a new Certified EHR Technology (CEHRT) threshold criterion to determine ACOs’ eligibility for program participation and retiring the current MSSP quality measure on the percentage of eligible clinicians using CEHRT.
     o    Allowing beneficiaries who voluntarily align to a Nurse Practitioner, Physician Assistant, Certified Nurse Specialist, or a physician with a specialty not used in assignment to be prospectively assigned to an ACO if the clinician they align with is participating in an ACO, as provided for in the Bipartisan Budget Act of 2018.
     o    Providing relief for ACOs and their clinicians impacted by extreme and uncontrollable circumstances in 2018 and subsequent years.
     o    Revising the definition of primary care services used in beneficiary assignment.

November 13, 2019
On November 1, 2019 the Centers for Medicare and Medicaid Services (CMS) released the calendar year (CY) 2020 Medicare Physician Fee Schedule (MPFS) final rule. This major final rule addresses: changes to the physician fee schedule (PFS); other changes to Medicare Part B payment policies to ensure that payment systems are updated to reflect changes in medical practice, relative value of services, Medicare Shared Savings and more. To understand how CMS modified its proposals as related to AAAAI feedback, and to review expert analysis of the final rule, offered by the AAAAI with consultants Hart Health Strategies.

September 26, 2019
AAAAI leadership recently submitted comments to the Centers for Medicare and Medicaid (CMS) in response to the Proposed 2020 Physician Fee Schedule and related revisions to the Quality Payment Program. Read more.

July 29, 2019
On July 29, the Centers for Medicare & Medicaid Services (CMS) released the DRAFT CY 2020 Medicare Physician Fee Schedule (MPFS). Overall, the A/I specialty is not expected to see a decrease in its total Medicare revenues, and the conversion factor – the value used to calculate total relative value units (RVUs) into payment rates - is up slightly at $36.0896. The AAAAI, with our expert consultants at Hart Health Strategies, continues to analyze the proposals. We will be sharing additional information soon, and will post our comments to be submitted to CMS in September.

Compare 2020 proposed reimbursement for allergy codes with 2019 reimbursement values. Review how CMS converts RVUs into compensation. To review CMS’ draft Evaluation and Management (E/M) code proposal from the 2020 proposed rule.

Key provisions of interest to the A/I community are highlighted below.

Evaluation and Management (E/M) Coding and Payment. Stepping back from its previously announced policies, CMS proposes to align its E/M coding policies consistent with recommendations by the AMA CPT Editorial Panel, and accept the associated AMA RUC recommended values. If finalized and implemented in CY 2021, CMS anticipates a 7% increase to A/I. To review the proposed new Evaluation and Management (E/M) codes.

Review and Verification of Medical Record Documentation. Last year, CMS finalized that a teaching physician could review and verify (sign/date) notes made by a medical student in a patient’s medical record for E/M services, rather than having to redocument the information. Given concerns raised by non-physician practitioners, CMS proposes to establish a general principle to allow the physician, the PA, or the APRN who furnishes and bills for their professional services to review and verify, rather than re-document, information included in the medical record by physicians, residents, nurses, students or other members of the medical team.
Care Management Services. CMS proposes to revise its billing requirements for transitional care management (TCM) services by allowing TCM codes to be billed concurrently with other key services, including prolong services without direct patient contact, complex chronic care management (CCM) services, and care plan oversight services. CMS also proposed to increase the work RVUs for certain TCM services, resulting in higher reimbursement when these services are delivered. CMS anticipates that this will lead to increased access to TCM services by Medicare beneficiaries. With regard to CMM services, CMS proposes to adopt two new G-codes for complex CCM services, as well as two new G-codes for non-complex CCM. These codes are anticipated to be replaced once the AMA CPT Editorial Panel completes revisions associated with these services. Last, CMS proposes two new codes for principal care management (PCM) services, which describe care management services for one serious chronic condition, and would be predominantly billed by specialists who are focused on managing patients with a single complex chronic condition requiring substantial care management.
Communication Technology-Based Services (CTBS). Last year, CMS finalized new codes and payment for CTBS (i.e., virtual check-in, evaluation of store and forward images, and interprofessional internet consultation). Hearing concerns that obtaining beneficiary consent for each discrete service is burdensome, CMS proposes that practices could use a single advance beneficiary consent.
Merit-based Incentive Payment System (MIPS). CMS proposes significant changes in the MIPS program, including an increase in the Cost performance category weight (from 15% to 20%) with a corresponding decrease in the Quality performance category weight (from 45% to 40%). With regard to quality measures, CMS is proposing to add a new quality measure – Adult Immunization Status – to the A/I specialty set, and remove the following measures – Influenza Immunization, Pneumococcal Vaccination Status for Older Adults, and Pneumocystis Jiroveci Pneumonia (PCP) Prophylaxis. AAAAI has advocated for the removal of other HIV/AIDS measures from the specialty set, and will continue to press for this revision in our formal comments. As a reminder, the AAAAI QCDR contains the most relevant measures for A/I practices, and captures other key data helpful to our efforts in demonstrating the safety of in-office compounding of allergenic extracts.
CMS also proposes modifications to the Qualified Clinical Data Registry (QCDR) measure standards for MIPS, which will require measure testing, harmonization, and clinician feedback. Given AAAAI’s considerable investment, we will work diligently to ensure requirements are reasonable, that our QCDR is compliant, and will continue to be available for A/I practices to use for MIPS and other research activities.

Finally, CMS requests information on a proposed framework for new MIPS Value Pathways (MVP), aimed at streamlining the MIPS program and making it more clinically relevant. While a potentially positive development that could assist A/I practices, CMS intends to employ administrative claims-based measures focused on population health, which may not be relevant to A/I practices and patients. AAAAI will work with the medical community on a coordinated response to ensure the new MVP can be a success.

Open Payments. As required by law, CMS proposes to include non-physician practitioners as “covered recipients” in its Open Payments program. This means PAs, NPs, CNSs, CRNAs, and CNMs would have data reported about their payments from industry in the Open Payments system. CMS also proposes to modify the nature of payment categories by consolidating separate distinctions for payments made to faculty at accredited/certified and unaccredited/non-certified continuing education programs into one “medical education programs” category, and establishing categories for debt forgiveness, long-term medical supply or device loan, and acquisitions.

AAAAI will continue to analyze the proposals and provide additional information soon. If you have questions or would like to flag key concerns about these proposals as they relate to your practice, we welcome your feedback at

November 15, 2018
Expert Analysis of 2019 Physician Fee Schedule Now Posted
Hart Health Services has completed their expert analysis of the Final 2019 Physician Fee Schedule. Compare the Final 2019 Physician Fee Schedule with the earlier fee schedule proposed by the Centers for Medicare and Medicaid Services (CMS). Review and compare 2018 and 2019 CMS reimbursement rates for relevant Current Procedural Terminology® (CPT) codes.

For the practicing allergist/immunologists, highlights of the Final 2019 Physician Fee Schedule include:
• For Calendar Year (CY) 2021, CMS is collapsing the payment variation for E/M office/outpatient visit levels by paying a single rate for E/M office/outpatient visit levels 2 through 4 for established and new patients, and is maintaining the payment rate for E/M office/outpatient visit level 5 to better account for the care and needs of complex patients. CMS estimates that the impact of the cumulative finalized policies will, on the whole, be cost-neutral.
• The national reimbursement rate for CPT 95165 (Professional services for the supervision of preparation and provision of antigens for allergen immunotherapy; single or multiple antigens) increased from $13.31 in CY 2018 to $14.41 in CY 2019.
• The CY Physician Fee Schedule conversion factor is 36.0391, a +0.11 percent increase over CY 2018.

For more information on how conversion factor, practice expense and RVU factors combine to determine reimbursement rates.

September 20, 2018
A bi-partisan group of Senators sent a letter today to CMS regarding the proposal to collapse E & M codes in the Medicare Physician Fee Schedule. The letter expresses concern about the impact on vulnerable patients with complex conditions and urges CMS to work collaboratively and with transparency with other stakeholders to explore alternatives to reduce physician burden while improving healthcare quality. The AAAAI is part of the coalition that secured this letter.

September 10, 2018

In response to the 2019 Proposed Medicare Physician Fee Schedule, the AAAAI expressed deep concern regarding the CMS’ proposed collapse of E/M services (Level 2-5); and urged CMS to reconsider Venom Immunotherapy and Antigen Costs, while also commenting upon the Quality Payment Program, and other aspects of the proposal.

Review the AAAAI letter.

To review the letter co-signed with the American College of Allergy, Asthma & Immunology, the Advocacy Council of the American College of Allergy, Asthma & Immunology and American Academy of Otolaryngic Allergy.

The Patient-Centered Evaluation and Management Services Coalition (Coalition), of which the AAAAI is a part, wrote to share concerns with the new evaluation and management (E/M) coding and payment proposals included in the Medicare Physician Fee Schedule Proposed Rule for Calendar Year 2019 (Rule). Read the letter to Members of Congress here. Read the letter to the Administration.

September 7, 2018

Read the “Dear Colleague” letter written with the support of a coalition of specialty societies concerned about the implications of the E&M proposal on both patient access and physician reimbursement. The AAAAI is a member of the coalition that secured this letter.