Dear Chairman Brady and Ranking Member Neal:
The undersigned organizations of the Alliance of Specialty Medicine (the Alliance), a coalition of medical specialty
societies representing more than 100,000 physicians and surgeons, write to express our deep concern with the
misvalued code offset provision included in the Medicare extenders package released on November 15. While
we appreciate the difficulty in obtaining appropriate offsets for this critical legislation, this offset unduly impacts
specialty physicians. We also object to any expansion of the Medicare budget sequester beyond 2022 or possible
additional cuts that could result from PAYGO violations.
The Alliance is very appreciative of the dedication of the congressional committees with Medicare jurisdiction in
crafting end of the year legislation to address Medicare extenders and other key health items. Previously, we
have expressed concerns about the misvalued code provisions, particularly since the work to identify potentially
misvalued services is ongoing through the American Medical Association’s (AMA) Relative Value System Update
Committee (RUC) and the Centers for Medicare and Medicaid Services (CMS). The vast majority of physician
services have been reviewed, resurveyed, and revalued, over the course of the last few years. Indeed, these
ongoing efforts have squeezed value out of most specialty codes to the point where the target set by Congress
cannot be met, resulting in reductions in the annual conversion factor for all physicians for the three consecutive
yearssince passage of the Achieving a Better Life Experience (ABLE) Act (P.L. 113-295). When added to the annual
two percent sequestration cut, we believe this provision is detrimental to the Medicare program and risks
inappropriately undervaluing physician services and threatening patient access to care. The Alliance, therefore,
urges its elimination.
The Alliance hopes to work with you to achieve an end of the year package of key health provisions that does not
include extending the misvalued codes provision.
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