Physician Fee Schedule 2018 Final Rule - December 11, 2017 powered by Vizient & AAMC
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Physician Fee Schedule 2018 Final Rule
December 11, 2017
© 2017 Vizient, Inc. and AAMC Page 1Audio:
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© 2017 Vizient, Inc. and AAMC Page 2Agenda
• Payment Policies and Other Policies
• Conversion Factors, Misvalued RVUs, RVU Targets
• Payment Rates for Provider-Based Off Campus Hospital
Departments
• Payment for Telehealth
• Other Proposals of Interest
• Appropriate Use Criteria for Advanced Diagnostic Imaging
• Patient Relationship Code Reporting
• Expansion of Diabetes Prevention Program
© 2017 Vizient, Inc. and AAMC Page 32018 Medicare Physician Fee Schedule Final Rule
• Displayed November 2, published in Federal Register November 15
https://www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-23953.pdf
• Supplemental materials (including RVU data)
https://www.cms.gov/Medicare/Medicare-Fee-for-Service-
Payment/PhysicianFeeSched/PFS-Federal-Regulation-Notices-Items/CMS-1676-F.html
© 2017 Vizient, Inc. and AAMC Page 4Physician Fee Schedule Final Rule
Proposed
Rule Final Rule
Proposed Rule Final rule
comment provisions
issued: July published:
deadline: effective:
12, 2017 September November
January 1,
15, 2017
11, 2017 2018
© 2017 Vizient, Inc. and AAMC Page 5Separate Quality Programs are all Sunsetting
PQRS
Meaningful
Use
Program
A New Consolidated
Pay-for-Performance
Value
Program under Modifier
Program
MACRA
Merit-Based Incentive
Payment System (MIPS)
© 2017 Vizient, Inc. and AAMC Page 6Fee Schedule Remains Bedrock of Payment
Fee Schedule
© 2017 Vizient, Inc. and AAMC Page 7Payment Policies © 2017 Vizient, Inc. and AAMC Page 8
Physician Fee Schedule (PFS) Updates • MACRA repealed Sustainable Growth Rate • PFS 0.5% update CY 2016-CY 2019 • PFS 0.0% update CY 2020-2025 • PFS updates 2026 and beyond: 0.75% for APM; 0.25% for MIPS • Merit-Based Incentive Payment System (MIPS) & participation in Alternative Payment Models will drive payment in 2019 and beyond © 2017 Vizient, Inc. and AAMC Page 9
MACRA Timeline © 2017 Vizient, Inc. and AAMC Page 10
Targets for “Misvalued” Code Reductions
ABLE Legislation
• 2016: 1.0% reduction
established 3 years • 2017: .5% reduction
of target reductions • 2018: .5% reduction
for misvalued codes
• If reductionstarget, then no adjustment to PFS,
amount over target is applied to next year’s target
2018 reduction did • Target recapture of -0.09 percent (CMS achieved
not meet the 0.5% .41% in reductions)
target
© 2017 Vizient, Inc. and AAMC Page 11Calculation of 2018 PFS Conversion Factor Conversion Factor 2017 $35.8887 Update Factor 0.50 percent (1.0050) 2018 RVU Budget -0.10 percent (0.9990) Neutrality adjustment 2018 Target Recapture -0.09 percent (0.9991) Amount 2018 Conversion Factor $35.9996 © 2017 Vizient, Inc. and AAMC Page 12
Malpractice RVUs: No change in final rule • In proposed rule, CMS discussed updating malpractice relative units with new premium data and specialty risk factors. (use of new data would have negatively impacted many specialists). • Concerns raised that the proposed valuation changes were not indicative of what is actually occurring in professional liability market. • In final rule, CMS decides not to update malpractice data. They will continue to use the same data collected for the 2015 MP RVU update. • The next update must occur by 2020. © 2017 Vizient, Inc. and AAMC Page 13
CMS Analysis of Specialty Impact
Social Worker (+ 3%) Diagnostic Testing Facility
Clinical Psychologist (+2%) (-4%)
Psychiatry (+1%) PT/OT (-2%)
Infectious disease (+1%) Independent labs (-1%)
Cardiology (+1%) Allergy/Immunology (-3%)
Vascular Surgery (-1%)
© 2017 Vizient, Inc. and AAMC Page 14Overview
• Coding changes (additions/deletions)
– Diagnostic radiology
– Artificial heart procedures and other Cardiology services
– Esophagectomy additions
– Collaborative care management
• Specialty impact
– Cardiology: Electrophysiology
– Cardiology: Noninvasive
– Pediatric Cardiology: Noninvasive
– Pediatric Cardiology
– Thoracic Surgery
• GPCI gains and losses
© 2017 Vizient, Inc. and AAMC Page 15New Radiology Chest and Abdominal
X-Ray Codes
. Chest x-ray CPT codes 71010-71035 (described as Abdominal x-ray CPT codes 74000-74020 deleted
‘stereo’) deleted Abdominal x-ray CPT codes added based on number
Chest x-ray CPT codes added based on number of of views
views, simplifying code selection.
Deleted CPT Codes New CPT Codes
CPT CPT
CPT Description 2017 wRVU CPT Description 2018 wRVU
Code Code
71010 Chest x-ray 1 view frontal 0.18 71045 X-ray exam chest 1 view 0.18
71015 Chest x-ray stereo frontal 0.21 71046 X-ray exam chest 2 views 0.22
71020 Chest x-ray 2vw frontal&latl 0.22 71047 X-ray exam chest 3 views 0.27
71021 Chest x-ray frnt lat lordotc 0.27 71048 X-ray exam chest 4+ views 0.31
71022 Chest x-ray frnt lat oblique 0.31
71023 Chest x-ray and fluoroscopy 0.38 X-ray exam abdomen 1
74018 0.18
71030 Chest x-ray 4/> views 0.31 view
71034 Chest x-ray&fluoro 4/> views 0.46 X-ray exam abdomen 2
74019 0.23
71035 Chest x-ray special views 0.18 views
X-ray exam abdomen 3+
74021 0.27
74000 X-ray exam of abdomen 0.18 views
74010 X-ray exam of abdomen 0.23
74020 X-ray exam of abdomen 0.27
© 2017 Vizient, Inc. and AAMC Page 16Total Heart Replacement System Codes
Move from Category III to Category I
• CPTs 33927-33929 replace 0051T-0053T Category III codes (emerging
technologies, services and procedures.
• 33927 will no longer be gap-filled and may receive fewer Work RVUs than in
2017
• 33928 and 33929 will be subject to FPSC gap-filling methodology
2018 2017
CPT Code CPT Description
wRVU wRVU*
33927 Impltj tot rplcmt hrt sys 49.00 53.26
33928 Rmvl & rplcmt tot hrt sys 0 0
33929 Rmvl rplcmt hrt sys f/trnspl 0 0
* wRVUs calculated using the FPSC gap-filling methodology
• Gap-filling is applied to codes with zero work, practice expense, and malpractice RVUs
• Locally weight ratio of charges to RVUs
© 2017 Vizient, Inc. and AAMC Page 17Esophagectomy
CPT codes 43286, 43287 and 43288 created to report
esophagectomy via laparoscopic and thoracoscopic approaches.
2018
CPT Code CPT Description
wRVU
43286 Esphg tot w/laps moblj 55.00
43287 Esphg dstl 2/3 w/laps moblj 63.00
43288 Esphg thrsc moblj 66.42
CPT codes 43107, 43112, and 43117 were also reviewed as part of
the family with the three new codes. CPT code 43112 was revised
to clarify the nature of the service being performed.
– Additional specialty impact information detailed in following slide
© 2017 Vizient, Inc. and AAMC Page 18Collaborative Care Management
Three new, time based codes for psychiatric collaborative care
management (CoCM):
2018
CPT Code CPT Description
wRVU
99492 1st psyc collab care mgmt; 70 min 1.70
99493 Sbsq psyc collab care mgmt; 60 min 1.53
99494 1st/sbsq psyc collab care; each additional 30 min 0.82
© 2017 Vizient, Inc. and AAMC Page 19Specialty Impacts © 2017 Vizient, Inc. and AAMC Page 20
Cardiology: Electrophysiology Observed
Overall Loss
% Variance (2018 vs. 2017)
Negative figures = reduction
Work RVU Non Facility Total RVU Facility Total RVU
per 1.0 cFTE per 1.0 cFTE per 1.0 cFTE
-3.1% -1.7% -1.8%
Mean Impact
CPT 2018 2017 wRVU %
CPT Description wRVU per 1.0 cFTE
Code wRVU wRVU Change Change
per MD
Dev interrog remote
93295 0.74 1.29 -0.55 -43% -169
1/2/mlt
Electrophys map 3d add-
93613 5.23 6.99 -1.76 -25% -132
on
© 2017 Vizient, Inc. and AAMC Page 21Adult and Pediatric Cardiology Echo
w/Doppler Accounts for Overall Increase
% Variance (2018 vs. 2017)
Negative figures = reduction
Mean Impact
Non Facility
Work RVU Facility Total RVU wRVU per
Specialty Total RVU
per 1.0 cFTE per 1.0 cFTE 1.0 cFTE
per 1.0 cFTE
per MD
Cardiology: Noninvasive +2.3% +2.0% +2.1% +174
Pediatric Cardiology: Noninvasive +2.0% +1.7% +1.8% +102
Pediatric Cardiology +1.3% +1.2% +1.2% +60
CPT 2018 2017 wRVU %
CPT Description
Code wRVU wRVU Change Change
93306 Tte w/doppler complete 1.50 1.30 +0.20 +15%
© 2017 Vizient, Inc. and AAMC Page 22Surgery Thoracic Displays Increase Due
to Esophagectomy wRVU Change
% Variance (2018 vs. 2017)
Negative figures = reduction
Work RVU Non Facility Total RVU Facility Total RVU
per 1.0 cFTE per 1.0 cFTE per 1.0 cFTE
+1.0% +0.6% +0.7%
Mean Impact
CPT 2018 2017 wRVU %
CPT Description wRVU per 1.0 cFTE
Code wRVU wRVU Change Change
per MD
Partial removal of
43117 57.50 43.65 +13.9 +32% +43
esophagus
43112 Removal of esophagus 62.00 47.48 +14.5 +31% +29
43107 Removal of esophagus 52.05 44.18 +7.9 +18% +16
© 2017 Vizient, Inc. and AAMC Page 23Geographic Pricing Cost Index (GPCI)
Gains and Losses
• Based on an average mix of Work, Practice Expense and Malpractice RVUs, we found
•
the following year-over-year changes from 2017 to 2018.
a
• The 1.0 Work GPCI floor required by Section 201 of the MACRA of 2015 expires on
December 31, 2017, therefore the Work GPCIs for 2018 do not reflect a 1.0 floor.
Decreases due to potential GPCI floor expiration
2018 2018 2018 Work 2018 2018 2018 Work
Locality Name Work PE MP GPCI Locality Name Work PE MP GPCI
GPCI GPCI GPCI % Change GPCI GPCI GPCI % Change
Oklahoma 0.961 0.891 0.954 -4% Metro Boston 1.033 1.179 1.061 1%
Rest of Missouri 0.961 0.863 0.993 -4%
San Francisco
Mississippi 0.961 0.870 0.370 -4% 1.075 1.325 0.421 1%
(Alameda/Contra Costa
West Virginia 0.966 0.857 1.296 -3% Cnty)
Kansas 0.966 0.911 0.615 -3% Los Angeles (Orange
Iowa 0.969 0.907 0.423 -3% 1.046 1.177 0.694 0.5%
County)
Indiana 0.969 0.919 0.379 -3%
Nebraska 0.970 0.910 0.318 -3%
Arkansas 0.971 0.872 0.576 -3%
Kentucky 0.974 0.880 0.819 -3%
© 2017 Vizient, Inc. and AAMC Page 24Background: Payment for Off-Campus
Provider-Based Hospital Departments
Section 603 of Bipartisan Budget Act of 2015 requires
payment for services furnished by off-campus provider
based departments under Part B system other than
Hospital Outpatient Prospective Payment System (OPPS).
The new payment rate policy does not apply to hospitals
that were furnishing covered OPD services before
November 2, 2015.
© 2017 Vizient, Inc. and AAMC Page 252017 Payment Rates for “Nonexcepted” Off
Campus Outpatient Hospital Departments
For 2017, CMS made the Physician Fee Schedule the
payment system and set payment rates based on a
50-percent reduction to the OPPS payment rates
(inclusive of packaging).
The adjustment is referred to as the “PFS Relativity
Adjuster”
Must report a modifier “PN” on each UB 04 claim line
to indicated nonexcepted items or service
© 2017 Vizient, Inc. and AAMC Page 262018 Payment Rates for Off-Campus Provider-
Based Hospital Departments
CMS proposed 75 percent reduction in
payment for nonexcepted services at off
campus OPDs (current reduction is 50 percent)
In response to comments, CMS finalizes a 60
percent reduction instead of 75 percent
proposed.
© 2017 Vizient, Inc. and AAMC Page 27Other Off Campus Hospital Provisions • CMS specifies that all beneficiary cost-sharing rules that apply under the PFS will continue to apply to all nonexcepted items and services furnished by off-campus OPDs • The supervision rules continue to apply to off campus departments that furnish nonexcepted services © 2017 Vizient, Inc. and AAMC Page 28
Evaluation and Management (E/M)
Documentation Guidelines
CMS invited comments on:
• Approaches to guideline revision that reduce burden and
leverage electronic health technology
• Revisions that deemphasize history and physician exam
performance
• Consideration of reducing or evening eliminating the history and
physical exam components at all E/M code levels.
• Extension of practitioner autonomy to determine volume of
documentation
• Guidelines structured to match documentation to patient
complexity (particularly medical decision-making)
© 2017 Vizient, Inc. and AAMC Page 29Evaluation & Management
Documentation Guidelines
AAMC Comments CMS Final Rule
• With increased use of EHR, and • CMS will consider these issues
movement to team-based care, for future rulemaking, but the
E&M guidelines impose a immediate focus will be on
significant administrative burden revision of current E&M
and are an impediment to good guidelines in an effort to reduce
patient care. unnecessary administrative
• For surgical/subspecialties, a burden.
comprehensive exam is not
always relevant.
• Determination of the level of
service should be based on
medical decision-making, not
time alone.
© 2017 Vizient, Inc. and AAMC Page 30Expansion of Telehealth Services
CMS finalized the addition of the following codes:
• HCPCS code G0296: Counseling visit to discuss
the need for lung cancer screening using LDCT
• CPT codes 90839 and 90840: Psychotherapy for
crisis; first 60 minutes
© 2017 Vizient, Inc. and AAMC Page 31Expansion of Telehealth Services
CMS finalized the addition of the following codes:
• CPT code 90785: Interactive complexity
• CPT codes 96160 and 96161: Administration of
patient-focused health risk assessment
instrument and Administration of caregiver-
focused health risk assessment instrument
• HCPCS code G0506: Comprehensive assessment
or/and care planning for patients requiring
chronic care management services
© 2017 Vizient, Inc. and AAMC Page 32Telehealth: Elimination of GT modifier • Effective January 1, 2017 Place of Service (POS) code 02 Telehealth is required on professional claims • CMS finalized the proposal to eliminate required use of the GT modifier on professional claims • Institutional claims, and federal telemedicine programs in AK and HI will need to continue using the GT modifier © 2017 Vizient, Inc. and AAMC Page 33
Telehealth: Remote Patient Monitoring • CMS activated separate payment for CPT code 99091, changing status from bundled • 99091: Collection and interpretation of physiological data digitally stored and/or transmitted by the patient and/or caregiver • Medicare allowed payment: $58.68 © 2017 Vizient, Inc. and AAMC Page 34
Appropriate Use Criteria (AUC) for Advanced
Diagnostic Services
Established by Protecting Access to Medicare Act of 2014
Criteria for physicians to better identify the appropriate advanced
diagnostic imaging service:
• Appropriate Use Criteria (AUC) must be developed by qualified provider-led
entities (list published in June 2016).
• Clinical decision support mechanism (CDSMs) are electronic tools physicians
will use to access the AUC to determine appropriateness of advanced diagnostic
imaging test.
• Requirement that in future ordering physicians must begin consulting CDSMs
and furnishing professionals must append AUC information about ordering
physician’s consultation to Medicare claim.
• Identification of Outlier physicians in the future.
© 2017 Vizient, Inc. and AAMC Page 35AUC Implementation CMS makes the AUC consultation and reporting requirements effective for an educational and operational testing period beginning on January 1, 2020. From mid-2018 through 2019, a voluntary physician participation period will run. In future, payment may only be made if the claim includes the proposed information required by furnishing professionals. It applies across the following payment systems (PFS, hospital outpatient, ASC) © 2017 Vizient, Inc. and AAMC Page 36
AUC Implementation: What is Required?
Furnishing Professional: Must
Ordering Professional
report the following
• Must consult AUC through • Must report:
qualified CDSMs for tests • Which qualified CDSM was
ordered on or after January consulted by ordering
1, 2020. professional
• (delayed from statutory • Whether service ordered
requirement of 2017). would adhere to AUC or
not, or whether AUC not
applicable; and
• NPI of ordering
professional
CMS will continue to pay claims whether or not they correctly include appropriate
information.
© 2017 Vizient, Inc. and AAMC Page 37New Coding Systems: MACRA
• Statute required claims submitted after Jan. 1, 2018
must include:
– Patient Condition Groups: Based on a patient’s chronic
conditions, current health status, and recent significant
history (e.g. hospitalization or surgery) (better risk
adjustment)
– Care Episode Groups: Create to define the types of
procedures or services furnished for particular clinical
conditions or diagnoses
– Patient Relationship categories: Distinguish the
relationship and responsibility of a physician with a patient
at the time of furnishing the item/service. (accountability)
© 2017 Vizient, Inc. and AAMC Page 38Patient Relationship Modifiers • Beginning January 1, 2018 claims for services provider may voluntarily submit claims with modifiers. • Duration of voluntary modifier reporting period is not specified. © 2017 Vizient, Inc. and AAMC Page 39
Patient Relationship HCPCS Modifiers and
Categories
Number Proposed HCPCS Modifier Patient Relationship
Categories
1x X1 Continuous/Broad Services
2x X2 Continuous/Focused
Services
3x X3 Episodic/Broad Services
4x X4 Episodic/Focused Services
5X X5 Only as Ordered by
Another Clinician
© 2017 Vizient, Inc. and AAMC Page 40Patient Relationship Modifiers
Relationship Category Description Example
Continuous/Broad Clinicians who provide the Primary care, specialists
principal care for a patient, providing comprehensive
where there is no planned care to patients in addition
endpoint of the relationship to specialty care, etc
Continuous/Focused Could include a specialist Rheumatologist taking care
whose expertise is needed of a patient’s rheumatoid
for the ongoing arthritis longitudinally but
management of a chronic not providing general
disease or a condition that primary care services
needs to be managed and
followed for a long time.
Episodic/Broad Clinicians that have broad Hospitalist providing
responsibility for the comprehensive and general
comprehensive needs of the care to a patient while
patients, but only during a admitted to the hospital.
defined period and
circumstance, such as a
hospitalization.
© 2017 Vizient, Inc. and AAMC Page 41Patient Relationship Modifiers
Relationship Category Description Example
Episodic/Focused A specialist focused on An orthopedic surgeon
particular types of time- performing a knee
limited treatment. replacement and seeing
the patient through the
postoperative period.
Only As Ordered By A clinician who furnishes A radiologist interpreting
Another Clinician care to the patient only as an imaging study ordered
ordered by another by another clinician
clinician.
© 2017 Vizient, Inc. and AAMC Page 422018 PQRS Payment Adjustment:
Finalized Modifications
• Reduced the number of required measures
from 9 measures across 3 domains to 6
measures with no domain requirement (does
not apply to Web Interface)
• Eliminated requirement to report cross-
cutting measure
• Eliminated requirement that group practices
of 100 or more EPS that use GPRO must
administer to CAHPS for PQRS patient survey.
© 2017 Vizient, Inc. and AAMC Page 432018 Value Modifier Program: Finalized
Modifications
Finalized modifications to VM policies for 2018 payment adjustment; would result in
fewer EPs and groups receiving negative VM adjustment & size of positive
adjustments would be reduced.
All groups and practitioners that avoid the PQRS payment reduction will be held
harmless from downward adjustments in quality tiering for 2018.
Adjustment for those who fail to report PQRS are reduced from -4% to -2% for groups
with 10 or more EPs and at least one physician. Reduced from -2% to -1% for groups
with between 2 and 9 Eps, physician solo practitioners, non-physician EP groups.
For groups with 10 or more EPs, maximum upward adjustment reduced from +4x to
+2x and average quality would reduce from 2.0x to 1.0x.
© 2017 Vizient, Inc. and AAMC Page 44Expansion of Medicare’s Diabetes
Prevention Program
© 2017 Vizient, Inc. and AAMC Page 45Medicare Diabetes Prevention Program (MDPP)
What: Structured health behavior change program delivered in community and health care settings
by training community health workers or health professionals, administered by Centers for Disease
Control (CDC)
Why: Diabetes affects more than 25% of Americans aged 65 or older and accounts for $104 billion
annually which are anticipated to grow by 2050
Who: Targets individuals with prediabetes (individuals who have blood sugar higher than normal but
not yet in the diabetes range)
Program Structure: Consists of 16 intensive “core sessions” of a CDC-approved curriculum in a group-
based setting that provides practical training in long-term dietary change, increased physical activity,
and problem solving strategies for overcoming challenges to sustaining weight loss and a healthy
lifestyle. Access to ongoing maintenance sessions after core benefit
Goal: Reduce incidence of Type 2 diabetes by achieving at least 5 percent average weight loss among
participants
© 2017 Vizient, Inc. and AAMC Page 46MDPP’s Finalized Requirements
CMS Finalized Requirements Beneficiaries Eligibility
Effective date beginning April 1, 2018 (instead of Pre-diabetic patient having a body mass index (BMI) of
January 1, 2018) 25 or greater (BMI of 23 for Asian beneficiaries)
Services begin April 1, 2018 Following blood levels:
Providers can begin enrolling January 1, 2018 Hemoglobin A1c test with a value of 5.7-6.4
12-month program using the CDC-approved DPP percent or;
curriculum a fasting plasma glucose of 110-125 mg/dL
Beneficiaries can only enroll in MDPP once within last 12 months or;
Beneficiaries who complete the 12 month program who 2-hour plasma glucose of 140-199 mg/dL after
achieve and maintain required weight loss can be the 75 gram oral glucose tolerance test
eligible for up to one year of monthly maintenance No previous diagnosis of diabetes (applies only at time
sessions as long as weight loss is maintained of the first core session)
Ongoing maintenance sessions adhere to the same
curriculum requirements as the course
Each MDPP session be at least an hour in duration
Existing Medicare providers and suppliers must submit a
separate enrollment application for MPDD services and
with national provider identification (NPI) required
© 2017 Vizient, Inc. and AAMC Page 47MDPP Reimbursement
• Number of
Two Sessions Attended
Factors • Achievement and
Maintenance of
Min. Weight Loss
© 2017 Vizient, Inc. and AAMC Page 48MDPP Reimbursement
Performance Goal Payment Per Beneficiary Payment Per Beneficiary
(with min. weight loss) (without min. weight
loss)
1 session attended $25
4 sessions attended $50
9 sessions attended $90
2 sessions attended in 1 st $60 $15
core maintenance session
interval (months 7-9)
Weight loss of 5% $160 $0
achieved
Advanced weight loss of $25 $0
9% achieved
Max Total Performance $670 $195
payment
© 2017 Vizient, Inc. and AAMC Page 49Diabetes Prevention Program: Social Risk
Factors
• CMS requested comments about social risk
factors in the context of the set of MDPP
services for future consideration.
• CMS will be reviewing comments made as
they consider additional policies surrounding
social risk factors in the future.
© 2017 Vizient, Inc. and AAMC Page 50Medicare Shared Savings Program Changes
Revises assignment
methodology for
Adds 3 new chronic care
assigning Medicare FFS
management codes and
beneficiaries to an ACO
behavioral health
based on utilization of
integration codes to
services furnished by
definition of primary care
rural health clinics and
services
federally qualified health
care centers.
Reduces burden for
submitting an initial Makes changes for
Shared Savings Program consistency with the
application and MIPS program reporting
application for use of SNF under MACRA
3 day waiver
© 2017 Vizient, Inc. and AAMC Page 51Resource links
Medicare Physician Fee Schedule Final Rule
https://www.gpo.gov/fdsys/pkg/FR-2017-11-15/pdf/2017-23953.pdf
CMS Fact Sheet on Medicare Physician Fee Schedule
https://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-
items/2017-11-02.html
AAMC Webpage: Physician Payment and Quality
https://www.aamc.org/initiatives/patientcare/patientcarequality/311244/physicianpayment
andquality.html
© 2017 Vizient, Inc. and AAMC Page 52Questions and Feedback
Questions and Feedback about PFS Final Rule
Gayle Lee, galee@aamc.org
Kate Ogden, kogden@aamc.org
FPSC Projects Related to PFS and Q&E
Dave Troland, David.Troland@vizientinc.com
Jake Langley, Jake.Langley@vizientinc.com
© 2017 Vizient, Inc. and AAMC Page 53You can also read