August 22, 2018


RE:  Proposed Calendar Year (CY) 2019 Medicare Physician Fee Schedule

The proposal from the Centers for Medicare and Medicaid Services (CMS) to collapse the current five levels of payments for office visits (Evaluation and Management) into two levels is a drastic change from the current system and appears to have been formulated without input from provider or beneficiary groups.

On behalf of the National Committee to Preserve Social Security and Medicare’s millions of members and supporters, we request you to withdraw this proposal and consider alternative ways of reducing unnecessary and burdensome paperwork and reporting requirements on physicians who want to spend more time treating their Medicare patients and less time on documentation.

Our opposition to the proposed single payment for Level II to Level V office visits is due to the adverse effects this proposed change would have on Medicare beneficiaries and the doctors caring for them.  We share the concerns that have been raised by physician stakeholders and allied senior advocacy organizations about the impact of the single payment proposal on patients, providers and federal spending, including:

  • Lower payments for Medicare beneficiaries requiring the highest intensity, lengthiest office visits could be a disincentive for providers to treat more complex, time-consuming patients.


  • Reduced payments could adversely impact primary care physicians who are treating patients with multiple chronic conditions or geriatricians and others who see older patients with many health/mental issues that require a significant amount of time to treat. And specialists, such as oncologists and rheumatologists, who deal mainly with complicated patients, are concerned about the lower reimbursements they would receive.


  • Avoiding the neediest patients or seeing them for shorter visits that don’t allow enough time to make good medical decisions could mean increased emergency room visits, hospitalizations or costly complications that would be detrimental to patients and would increase federal health spending.


  • Patients could be asked to come back for multiple shorter visits which would be inconvenient for patients and would increase out-of-pocket costs (or supplemental insurance costs) for the 20 percent Part B copayment.  In addition, copayments for Level II and III visits would increase along with the increased payment for them.


  • Some doctors who receive lower payments from Medicare under the proposed changes might choose to stop seeing Medicare patients altogether, creating access challenges for some beneficiaries. And some medical students might not select primary care or specialties that do not perform procedures.


CMS’ proposed changes would adversely impact Medicare beneficiaries and providers and should be withdrawn.  If not, it would be better to start with a small demonstration project that includes a focus on ways to ensure patients with greater health care needs don’t face greater challenges in access to doctors due to payment incentives.