MGMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed 2021 Medicare Physician Fee Schedule (PFS). Our comprehensive comments address the direct concerns and feedback we have heard from members, particularly as they continue to face challenges resulting from the COVID-19 pandemic. In our comments, MGMA recommends that CMS:

• Continue to reimburse audio-only remote visits at a rate that adequately covers the cost of care.
• Move forward with implementing improvements to Evaluation and Management office visits on Jan. 1, 2021, but take action to prevent physician payment cuts due to budget neutrality adjustments.
• Delay proposed changes to Medicare Shared Savings Program ACO quality reporting.
• Implement an automatic hardship exception for participants in the Merit-based Incentive Payment System for the 2020 and 2021 performance years, similar to the policy implemented for the 2019 performance year.