Chairman Brady, Ranking Member Neal, Chairman Walden, Ranking Member Pallone, Chairman Hatch,
and Ranking Member Wyden:
The undersigned members of The Patient-Centered Evaluation and Management Services Coalition
(Coalition) write to share our 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). While we commend the Centers for Medicare and Medicaid Services’ (CMS) efforts to
reduce documentation burden, we are very concerned about the payment proposals and request that
your committees take action to urge CMS to withdraw the E/M coding and payment proposals included
in the Medicare Physician Fee Schedule Proposed Rule for Calendar Year 2019 (Rule).
e have significant concerns that the coding and payment aspects of the Rule, as currently framed, will
have unintended consequences that will negatively impact patient access to appropriate care and
should not be made final this year. For example, CMS proposes new codes that, while well-intentioned,
are vague and could create new documentation burdens for practitioners. Implementation of any new
coding structure requires substantial physician and office staff education and changes to our electronic
health records systems, as well as changes for Medicare contractors and auditors. The undersigned
medical professional societies and other stakeholders ask that any proposals to reform payment,
including the proposed modifier 25 reimbursement reduction policy and coding for office visits, be
withdrawn so we can work with CMS on a consensus-based coding structure the agency can implement
in 2020 or 2021 without disrupting patient care and medical practice in your community.
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