In Comments on 2019 Medicare Fee Schedule Proposal, AGS Calls for Putting Older People First

November 7, 2018

American Geriatrics Society (AGS)

In a letter sent to the Centers for Medicare & Medicaid Services (CMS)1 and described earlier this fall in an extensive editorial for the Journal of the American Geriatrics Society, the American Geriatrics Society (AGS) voiced strong opposition to a proposal that would significantly change the way physicians and other qualified health professionals are paid for Evaluation and Management (E/M) services under the Medicare Physician Fee Schedule proposed rule. E/M services, which form the foundation for geriatrics’ hallmark approach to high-quality, person-centered, and team-based care for older people, include diagnosing and managing chronic conditions, treating acute illness, developing care plans, coordinating care across providers and settings, and discussing an older person’s preferences for care.

According to AGS experts, the proposal outlined by CMS presents a high risk for significant unintended consequences and could negatively impact patient care, especially for people with complex care needs.

Specifically, the CMS proposal would alter the present system by creating a single-rate payment for almost all E/M outpatient office visits irrespective of the visit’s length or complexity. In effect, such a change would slash reimbursement for providers who care for older people, offering the same pay for all patients, even those who may need more time and attention from their health professionals. Among several concerns, AGS experts worry the proposed changes could lead to shorter patient visits and visits on separate days, neither of which support coordinated care for people who benefit from time-intensive services and support.

“In our AGS letter to CMS, we noted our strong support for efforts to reduce administrative burden, and recommended finalizing a number of proposed changes to documentation requirements beginning in 2019,” Nancy E Lundebjerg, MPA, chief executive officer of the AGS, observed.1 “But we strongly urged CMS to withdraw all of its proposals related to payment for E/M services, and recommended that CMS engage with stakeholders to develop a refined approach that would achieve the best possible outcome for patients.”

In addition to drafting its own letter to CMS, the AGS led a multispecialty coalition of like-minded medical societies. Together, coalition members developed 2 letters. The first was a joint letter to CMS signed by 41 organizations detailing concerns with the proposed changes to E/M payment and reiterating recommendations that CMS withdraw its payment proposal and work with stakeholders on more effective solutions.2 The second letter, signed by 40 organizations, urged House and Senate Committees to reach out to CMS directly to reinforce the concerns voiced by coalition members.3 Separately, the AGS and other stakeholders also met with members of Congress to educate them on what the proposed changes could mean for Medicare beneficiaries.

“Our understanding from various stakeholder meetings is that CMS recognizes our significant concerns and is reflecting on potential ways to work collaboratively on a solution as a result of our collective efforts,” Ms Lundebjerg summarized. “We are hopeful this means CMS will not move forward with its proposed changes to E/M payment in 2019.” 

Outside the payment proposal, the AGS did commended CMS efforts to reduce the administrative burden associated with documentation requirements for E/M services but continued to note that these positive steps forward could be overshadowed by changes to E/M payment if finalized as written. The comments were submitted in response to the Medicare Physician Fee Schedule Proposed Rule for 2019 (released in July 2018), a regulatory document which outlines proposed Medicare payment rates and other payment policies for the upcoming calendar year. The final rule is slated for release imminently.

The AGS comment letters are available at; the related article describing the AGS process for assessing the fee schedule and providing AGS commentary is available for free at


1. American Geriatrics Society. Letter to CMS on CY 2019 Physician Fee Schedule and Quality Payment Program Proposed Rule (September 10, 2018). Accessed October 25, 2018.

2. American Geriatrics Society. Multispecialty Coalition Letter to CMS on E/M Proposals in CY 2019 Physician Fee Schedule Proposed Rule (September 10, 2018). Accessed October 25, 2018.

3. American Geriatrics Society. Multispecialty Coalition Letter to Congress on CMS E/M Proposals in CY 2019 Physician Fee Schedule Proposed Rule (September 10, 2018). Accessed October 25, 2018.

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