American College of Rheumatology Urges CMS to Reject Proposed Same-Day E/M Payment Cut, Address Broader Reimbursement Concerns
ATLANTA – The American College of Rheumatology (ACR) has submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to its proposed 2027 Medicare Physician Fee Schedule (MPFS). The comments specifically express concern with yet another year of cuts to the annual conversion factor (CF) and the new policy proposal to limit payment for separately identifiable evaluation and management (E/M) services furnished the same day as select procedures.
"Year after year, the ACR has called for a more sustainable Medicare payment system that allows rheumatologists to sustain their practices and protect their ability to provide care for patients," said William F. Harvey, MD, MSc, FACR, president of the ACR. "Unfortunately, this year's proposed rule is more of the same, perpetuating chronic Medicare underpayment that will make it harder for rheumatology practices to maintain access to care – especially for patients with complex, chronic rheumatic diseases."
The ACR opposes a new policy introduced in the 2027 proposed rule that would cut payment in half for less expensive services when an E/M visit is delivered on the same day as a 0-, 10- or 90-day global surgical procedure. In rheumatology, a medically necessary procedure and a significant, separately identifiable E/M service occurring on the same day is not an uncommon occurrence, meaning—if implemented—rheumatologists will be disproportionately impacted by this policy. Instead, the letter argues that “payment for services should be determined based on medical necessity and the nature of the work required, not the location or timing of the service.” Additionally, the ACR asks that CMS continue to monitor the impact of other E/M changes for unintended consequences to practices and patient access.
The letter also expresses concern for yet another decrease to the annual Medicare conversion factor (CF), noting that the cut particularly hurts rheumatologists as CMS reimburses more for individual procedures than for cognitive care. The ACR is advocating for fixes from lawmakers in Congress to address the flawed Medicare physician payment structure to account for inflation, raise Medicare’s budget neutrality threshold and eliminate some of the administrative burden currently placed on physicians. The Patients First Act (H.R. 9693), introduced by Representatives John Joyce, MD, Greg Murphy, MD, and Kim Schrier, MD, is a bipartisan bill supported by the ACR that would implement Medicare physician payment reform and strengthen patient access to care. The letter urges “CMS to work with Congress towards a permanent, inflation-adjusted system for Medicare physician reimbursement,” noting that “further decreases in the conversion factor are unsustainable.”
Finally, the ACR shared considerations for CMS as the agency refines the MIPS Value Pathways (MVPs) quality reporting program. While the ACR supports the administration’s goals of improving alignment, reducing reporting burden, and supporting value-based care, there is also concern that transitions in the program would lead to high costs and administrative burdens- especially for small, rural, or independent practices. The letter instead advocates for continued support for specialty-specific MVPs developed with relevant stakeholder input.
“Patients living with rheumatic diseases should not have to suffer because of payment policies that make it harder for physicians to keep their practices open. It’s time for policymakers to support changes that preserve access to comprehensive care while also ensuring physicians are fairly reimbursed for the services provided. The proposed rule fails to meet those goals,” Dr. Harvey concluded.
Media Contact
Teri Arnold
Director, Public Relations & Communications
757-272-7002
tarnold@rheumatology.org
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About the American College of Rheumatology
Founded in 1934, the American College of Rheumatology (ACR) is a not-for-profit, professional association committed to advancing the specialty of rheumatology that serves nearly 10,500 physicians, health professionals, researchers and scientists worldwide. In doing so, the ACR offers education, research, advocacy and practice management support to help its members continue their innovative work and provide quality patient care. Rheumatology professionals are experts in the diagnosis, management and treatment of more than 100 different types of arthritis and rheumatic diseases.