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Representatives Respond to Medicare Reimbursement Proposal Concerns

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NEWS RELEASE

As thousands of physicians, including those providing infectious diseases and HIV care, cited damaging impacts of a Centers for Medicare & Medicaid Services proposal to slash reimbursements for evaluation and management of complex cases, lawmakers are signing onto a letter asking the agency to delay action on the move. The letter, launched by Representatives Earl Blumenauer (D-OR), Brad Wenstrup (R-OH), Marsha Blackburn (R-TN) and Doris Matsui (D-CA) asks the Centers to allow time for medical groups and others affected by the proposal to develop an improved alternative to the proposed rule change.

The current proposal, released in July, would collapse the number of levels determining reimbursement for physicians’ evaluation and management of patients through face-to-face encounters from the current 10 levels (five levels for new patients, and five for established patients) to just two levels for each of the two categories of patients. Proposed with the stated intention of reducing administrative paperwork, the new structure would differentiate only between the most routine and easily managed cases, and complex cases that can include patients with multiple infections, conditions that compromise immunity, antibiotic resistance, post-transplant care, and psychosocial issues as well as other conditions that may challenge access to care and the success of treatments. The resulting reimbursements would be slightly higher for the first, simpler level, but lead to a nearly 40 percent reduction in reimbursement to physicians providing the most complex care through face to face evaluation and management. Evaluation and management, or E/M, accounts for more than 90 percent of care provided by infectious diseases and HIV physicians.

Infectious diseases and HIV physicians earn significantly less than the average of physicians in other specialties, and frequently less than those in general practice, while undergoing two to three years of additional training. In responses that continue to accrue on the Centers for Medicare and Medicaid Services public comments site, infectious diseases and HIV physicians have cited the powerful disincentive the proposal, and the diminished reimbursements it would offer for comprehensive patient care, would pose to future doctors weighing entry into an already challenging field. Studies have shown that the existing compensation gap has been cited as a key factor behind a more than 20-percent decline in the numbers of physicians entering training for the ID specialty from 2011-2016, and the Centers for Disease Control and Prevention has predicted that a shortage of HIV clinicians could challenge access to care by 2019. Commenters have noted that a further reduction in the ranks of infectious diseases physicians will compromise national capacities to respond to new outbreaks, as well as rising rates of antimicrobial resistance and spikes in infectious diseases linked to the opioid epidemic.

In addition, physicians have cited the impacts of the proposal on current patient care, saying that by supporting simpler levels of care it would necessitate multiple patient visits to address medical issues.

The Representatives’ letter, now being circulated among Members of Congress, expresses concern that the proposal was made with little input from physicians and undervalues the time and expertise of those who treat patients with complex conditions.

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