RE: Medicare Program; Revisions to Payment Policies under the Physician Fee
Schedule and Other Revisions to Part B for CY 2018; Medicare Shared Savings Program
Requirements; and Medicare Diabetes Prevention Program (CMS-1676-P)
Dear Ms. Verma,
The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty
physicians from 13 specialty and subspecialty societies. The Alliance is deeply committed to
improving access to specialty medical care through the advancement of sound health policy.
For this reason, we are pleased to provide input on the 2018 Medicare Physician Fee Schedule
(MPFS) proposed rule, which focuses on the impact of proposals on specialty physicians and the
beneficiaries they serve.
Potentially Misvalued Services
Code screens
Specialty societies in the Alliance have noted that certain codes are continuously captured in
CMS’ code screens and proposed as potentially misvalued year-after-year, despite the fact that
the codes may have been proposed as potentially misvalued in a prior year and removed from
the list. The time and effort expended to research and prepare substantive comments to
convince the agency that certain codes should be removed from the list is a significant and
resource-intensive activity that takes away from other important mission-driven efforts of our
member organizations.
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