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Medicare Advocacy

The AAO-HNS has a long history of working closely with the U.S. Department of Health and Human Services, the Centers for Medicare & Medicaid Services (CMS), and the CMS Innovation Center to maintain our visibility and credibility with national representatives regarding Medicare issues.

We believe that advocacy is the key to defining the future of otolaryngology. Medicare regulatory advocacy is a top priority of the AAO-HNS.

AAO-HNS Submits Comments on Medicare Physician Fee Schedule Proposed Rule

On September 10, the AAO-HNS submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) addressing several components of the CY 2019 Medicare Physician Fee Schedule (MPFS) proposed rule. The Academy’s comments focused on Medicare’s proposed changes to documentation requirements, coding and payment for Evaluation and Management (E/M) services, application of the MPPR to E/M services, and the pricing and composition of balloon sinus surgery kits. View the letter here.

CMS Releases CY 2019 MPFS/QPP Proposed Rule

On July 12, 2018, the Centers for Medicare & Medicaid Services (CMS) released the CY 2019 Proposed Rule for the Medicare Physician Fee Schedule (MPFS). While in previous years regulations for the Quality Payment Program (QPP) were released independently, the 2019 MPFS proposed rule includes proposals related to Medicare physician payment, as well as the QPP. You may view the proposed rule here

CMS proposes an updated CY 2019 conversation factor of $36.0463, which reflects the 0.25 percent update specified by the Medicare Access and CHIP Reathorization Act (MACRA) and a budget neutrality adjustment of -0.12 percent. Overall, this is a slight increase from the current conversion factor of $35.9996.

While the AAO-HNS physician leaders and staff are still reviewing the nearly 1,500 pages of the proposed rule, a few items specifically impacting the specialty should be noted. First, the rule proposes replaces existing E/M coding documentation guidelines for office and outpatient visits and collapsing payments from five levels to either two or three levels. Further, the rule proposes a 50 percent multiple procedure reduction when reporting an E/M service and a procedure on the same date.

The Merit-based Incentive Payment System (MIPS) portion of the proposed rule retains the low-volume threshold, but adds a third criteria of providing <200 covered professional services to Part B patients, as well as an opt-in mechanism. Payment adjustments could be as high as +7 percent or as low as -7 percent, and eligible clinicians must use the 2015 Edition certified EHR technology (CEHRT) in Year 3. The rule also further modifies the weighting for the four performance categories:

  • Quality: 45%
  • Cost: 15%
  • Promoting Interoperability (formerly Advancing Care Information): 25%
  • Improvement Activities: 15%

To review a more in-depth review of requirements for Year 3 of the QPP (CY 2019), visit

The Academy plans to submit comprehensive comments to CMS by the September 10 deadline.