Comment Letter | Medicare Payment and Reimbursement

HFMA Comments on the CY 2019 Physician Fee Schedule Proposed Rule

Comment Letter | Medicare Payment and Reimbursement

HFMA Comments on the CY 2019 Physician Fee Schedule Proposed Rule

HFMA submits comments to CMS on the CY 2019 Medicare Physician Fee Schedule Proposed Rule, published in the July 27, 2018, Federal Register.

HFMA would like to commend CMS for its thorough analysis and discussion of the myriad Medicare reimbursement decisions addressed in the 2019 Proposed Rule. Our members would like to comment on the proposals related to the following:


  • Minimizing Documentation Requirements by Simplifying Payment Amount
  • MIPS Proposed Addition of Low-Volume Threshold Criterion Based on Number of Covered Professional Services; Low-Volume Threshold Opt-In
  • MIPS Performance Category Measures and Activities
  • MIPS Facility-Based Measurement
  • Exclusion of MIPS Eligible Clinicians Participating in the Medicare Advantage Qualifying Payment Arrangement Incentive (MAQI) Demonstration
  • Identification and Review of Potentially Misvalued Services
  • Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging  Services
  • Request for Information on Price Transparency: Improving Beneficiary Access to Provider and Supplier Charge Information

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