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. 

Contact Us Today

Recent Articles and News

October 02, 2019

More Myths and Misconceptions Around ACO Success

Don’t Let Misunderstandings about ACOs Hold You Back from Value-Based Care Success There is no better time to join an ACO than right now, but providers must cut through a lot of noise to get to the truth about the benefits of being in an ACO.

ACO

September 20, 2019

Year Two Results for ACO Investment Model Show Rural Value-Based Payment is Stronger Than Ever

Last week, CMS published the second year evaluation of the ACO Investment Model (AIM). AIM provided two years of upfront funds to smaller rural accountable care organizations venturing into value-based payment.

ACO, News, Policy

May 07, 2019

CMS Unveils New Primary Care Value-Based Payment Models to Start in 2020

In late April, CMS introduced five new value-based payment model options that aim to transform primary care and shift providers to take risk on the cost of care for their patients.

ACO, News, Policy, CMS