Caravan Health sent a comment letter on CMS’s proposed Medicare Physician Fee Schedule and Quality Payment Program rule for the 2019 performance year. We published our initial thoughts on the proposal in a blog post here. You can see the full comments in our letter here.


The letter reflects our experience supporting ACOs, including many composed of rural health systems focused on population health. We appreciate CMS’s efforts to streamline and simplify billing for physicians but have concerns that the proposed restructure of Evaluation and Management billing creates an incentive for providers to avoid patients with complex health needs. We also urge CMS not to apply a payment reduction to annual wellness visits, which are a cornerstone of population health for Medicare patients.  

Our letter also comments on: 

  • The new code for the virtual check-in 

  • Shared Savings Program quality measure set 

  • Changes to Promoting Interoperability category

 

For questions about Caravan's comment letter, fill out a form to speak with an expert. 

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