CY2019 Physician Fee Schedule and Quality Payment Program Proposed Rule Comments

Summary: On September 7, 2018, PAEA submitted comments to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma regarding the CY2019 Physician Fee Schedule proposed rule. The letter requests that CMS recognize the Medicare Claims Processing Manual definition of “student,” which includes PA students, thereby allowing teaching physicians to verify PA student documentation instead of re-documenting the information as required under current policy.

In addition, PAEA argued that, by revising the eligibility criteria for improvement activity IA_AHE_6 per the CY2018 Quality Payment Program final rule, CMS could expand the activity’s overall impact on health equity by increasing the number of clinical sites available to PA students. To this end, the letter encourages CMS to allow preceptors outside of small, rural, and underserved practices to benefit from the improvement activity via future rulemaking.