Last year, on behalf of its members, the APWCA submitted a comment letter to CMS regarding the 2019 Medicare Part B Physician Fee Schedule. A copy of the full letter is attached below.

The APWCA argued against:

• Consolidation of payment for levels 2-5 office and other outpatient E/M services
• New E/M codes for “podiatry services”
• The application of the MPPR concept to E/M coding
• The raise to 30 of the score needed to avoid a MIPS penalty
• Change to the small practice MIPS bonus

The APWCA commented on some specific RVUs and responded to their request for information regarding postoperative visits following 10 day global procedures.

Final APWCA 19 MPFS Comment Letter.pdf