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© 2017 Vizient, Inc. and AAMC Page 1
Physician Fee Schedule 2018 Final Rule
December 11, 2017
powered by Vizient & AAMC
© 2017 Vizient, Inc. and AAMC Page 2
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© 2017 Vizient, Inc. and AAMC Page 3
Agenda
• 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 4
2018 Medicare Physician Fee Schedule Final Rule
• Displayed November 2, published in Federal Register November 15https://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 5
Physician Fee Schedule Final Rule
Proposed Rule issued: July
12, 2017
Proposed Rule
comment deadline:
September 11, 2017
Final rule published: November
15, 2017
Final Rule provisions effective: January 1,
2018
© 2017 Vizient, Inc. and AAMC Page 6
Separate Quality Programs are all Sunsetting
A New Consolidated Pay-for-Performance
Program under
MACRA
Merit-Based Incentive Payment System (MIPS)
Value Modifier Program
Meaningful Use
Program
PQRS
© 2017 Vizient, Inc. and AAMC Page 7
Fee Schedule Remains Bedrock of Payment
Fee Schedule
© 2017 Vizient, Inc. and AAMC Page 8
Payment Policies
© 2017 Vizient, Inc. and AAMC Page 9
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• MACRA repealed Sustainable Growth Rate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 10
MACRA Timeline
© 2017 Vizient, Inc. and AAMC Page 11
Targets for “Misvalued” Code Reductions
• 2016: 1.0% reduction
• 2017: .5% reduction
• 2018: .5% reduction
ABLE Legislation established 3 years of target reductions for misvalued codes
• If reductions<target, then all PFS services reduced by difference
• If reductions>target, then no adjustment to PFS, amount over target is applied to next year’s target
Calculation
• Target recapture of -0.09 percent (CMS achieved .41% in reductions)
2018 reduction did not meet the 0.5%
target
© 2017 Vizient, Inc. and AAMC Page 12
Calculation of 2018 PFS Conversion Factor
Conversion Factor 2017 $35.8887
Update Factor 0.50 percent (1.0050)
2018 RVU Budget Neutrality adjustment
-0.10 percent (0.9990)
2018 Target Recapture Amount
-0.09 percent (0.9991)
2018 Conversion Factor $35.9996
© 2017 Vizient, Inc. and AAMC Page 13
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 14
CMS Analysis of Specialty Impact
Social Worker (+ 3%)
Clinical Psychologist (+2%)
Psychiatry (+1%)
Infectious disease (+1%)
Cardiology (+1%)
Diagnostic Testing Facility
(-4%)
PT/OT (-2%)
Independent labs (-1%)
Allergy/Immunology (-3%)
Vascular Surgery (-1%)
© 2017 Vizient, Inc. and AAMC Page 15
Overview
• 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 16
.
New Radiology Chest and Abdominal X-Ray Codes
New CPT Codes
CPT
CodeCPT Description 2018 wRVU
71045 X-ray exam chest 1 view 0.18
71046 X-ray exam chest 2 views 0.22
71047 X-ray exam chest 3 views 0.27
71048 X-ray exam chest 4+ views 0.31
74018X-ray exam abdomen 1
view0.18
74019X-ray exam abdomen 2
views0.23
74021X-ray exam abdomen 3+
views0.27
Deleted CPT Codes
CPT
CodeCPT Description 2017 wRVU
71010 Chest x-ray 1 view frontal 0.18
71015 Chest x-ray stereo frontal 0.21
71020 Chest x-ray 2vw frontal&latl 0.22
71021 Chest x-ray frnt lat lordotc 0.27
71022 Chest x-ray frnt lat oblique 0.31
71023 Chest x-ray and fluoroscopy 0.38
71030 Chest x-ray 4/> views 0.31
71034 Chest x-ray&fluoro 4/> views 0.46
71035 Chest x-ray special views 0.18
74000 X-ray exam of abdomen 0.18
74010 X-ray exam of abdomen 0.23
74020 X-ray exam of abdomen 0.27
Chest x-ray CPT codes 71010-71035 (described as ‘stereo’) deleted
Chest x-ray CPT codes added based on number of views, simplifying code selection.
Abdominal x-ray CPT codes 74000-74020 deleted
Abdominal x-ray CPT codes added based on number of views
© 2017 Vizient, Inc. and AAMC Page 17
• 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
Total Heart Replacement System Codes
Move from Category III to Category I
CPT Code CPT Description2018
wRVU
2017
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 18
CPT codes 43286, 43287 and 43288 created to report
esophagectomy via laparoscopic and thoracoscopic approaches.
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
Esophagectomy
CPT Code CPT Description2018
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
© 2017 Vizient, Inc. and AAMC Page 19
Three new, time based codes for psychiatric collaborative care
management (CoCM):
Collaborative Care Management
CPT Code CPT Description2018
wRVU
99492 1st psyc collab care mgmt; 70 min 1.70
99493 Sbsq psyc collab care mgmt; 60 min 1.53
99494 1st/sbsqpsyc collab care; each additional 30 min 0.82
© 2017 Vizient, Inc. and AAMC Page 20
Specialty Impacts
© 2017 Vizient, Inc. and AAMC Page 21
Work RVU
per 1.0 cFTE
Non Facility Total RVU
per 1.0 cFTE
Facility Total RVU
per 1.0 cFTE
-3.1% -1.7% -1.8%
Cardiology: Electrophysiology Observed Overall Loss
% Variance (2018 vs. 2017)
Negative figures = reduction
CPT
CodeCPT Description
2018
wRVU
2017
wRVU
wRVU
Change
%
Change
Mean Impact
wRVU per 1.0 cFTE
per MD
93295Dev interrog remote
1/2/mlt0.74 1.29 -0.55 -43% -169
93613Electrophys map 3d add-
on5.23 6.99 -1.76 -25% -132
© 2017 Vizient, Inc. and AAMC Page 22
SpecialtyWork RVU
per 1.0 cFTE
Non Facility
Total RVU per 1.0 cFTE
Facility Total RVU
per 1.0 cFTE
Mean Impact
wRVU 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
Adult and Pediatric Cardiology Echo w/Doppler Accounts for Overall Increase
% Variance (2018 vs. 2017)
Negative figures = reduction
CPT
CodeCPT Description
2018
wRVU
2017
wRVU
wRVU
Change
%
Change
93306 Tte w/doppler complete 1.50 1.30 +0.20 +15%
© 2017 Vizient, Inc. and AAMC Page 23
Work RVU
per 1.0 cFTE
Non Facility Total RVU
per 1.0 cFTE
Facility Total RVU
per 1.0 cFTE
+1.0% +0.6% +0.7%
Surgery Thoracic Displays Increase Due to Esophagectomy wRVU Change
% Variance (2018 vs. 2017)
Negative figures = reduction
CPT
CodeCPT Description
2018
wRVU
2017
wRVU
wRVU
Change
%
Change
Mean Impact
wRVU per 1.0 cFTE
per MD
43117Partial removal of
esophagus57.50 43.65 +13.9 +32% +43
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 24
• 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.
Geographic Pricing Cost Index (GPCI) Gains and Losses
Locality Name2018
Work GPCI
2018
PE GPCI
2018
MP GPCI
Work
GPCI % Change
Oklahoma 0.961 0.891 0.954 -4%
Rest of Missouri 0.961 0.863 0.993 -4%
Mississippi 0.961 0.870 0.370 -4%
West Virginia 0.966 0.857 1.296 -3%
Kansas 0.966 0.911 0.615 -3%
Iowa 0.969 0.907 0.423 -3%
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%
Locality Name2018
Work GPCI
2018
PE GPCI
2018
MP GPCI
Work
GPCI % Change
Metro Boston 1.033 1.179 1.061 1%
San Francisco
(Alameda/Contra Costa
Cnty)
1.075 1.325 0.421 1%
Los Angeles (Orange
County)1.046 1.177 0.694 0.5%
Decreases due to potential GPCI floor expiration
© 2017 Vizient, Inc. and AAMC Page 25
Background: 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 26
2017 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 27
2018 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 28
Other 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 29
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 30
Evaluation & Management Documentation Guidelines
AAMC Comments
• With increased use of EHR, and movement to team-based care, E&M guidelines impose a significant administrative burden and are an impediment to good patient care.
• For surgical/subspecialties, a comprehensive exam is not always relevant.
• Determination of the level of service should be based on medical decision-making, not time alone.
CMS Final Rule
• CMS will consider these issues for future rulemaking, but the immediate focus will be on revision of current E&M guidelines in an effort to reduce unnecessary administrative burden.
© 2017 Vizient, Inc. and AAMC Page 31
Expansion 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 32
Expansion 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 33
Telehealth: 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 34
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 35
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 36
AUC 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 37
AUC Implementation: What is Required?
Ordering Professional
• Must consult AUC through qualified CDSMs for tests ordered on or after January 1, 2020.
• (delayed from statutory requirement of 2017).
Furnishing Professional: Must report the following
• Must report:
• Which qualified CDSM was consulted by ordering professional
• Whether service ordered 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 38
New 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 39
Patient 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 40
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 41
Patient Relationship ModifiersRelationship Category Description Example
Continuous/Broad Clinicians who provide the principal care for a patient, where there is no planned endpoint of the relationship
Primary care, specialists providing comprehensive care to patients in addition to specialty care, etc
Continuous/Focused Could include a specialist whose expertise is needed for the ongoing management of a chronic disease or a condition that needs to be managed and followed for a long time.
Rheumatologist taking care of a patient’s rheumatoid arthritis longitudinally but not providing general primary care services
Episodic/Broad Clinicians that have broad responsibility for the comprehensive needs of the patients, but only during a defined period and circumstance, such as a hospitalization.
Hospitalist providing comprehensive and general care to a patient while admitted to the hospital.
© 2017 Vizient, Inc. and AAMC Page 42
Patient Relationship Modifiers
Relationship Category Description Example
Episodic/Focused A specialist focused on particular types of time-limited treatment.
An orthopedic surgeon performing a knee replacement and seeing the patient through the postoperative period.
Only As Ordered By Another Clinician
A clinician who furnishes care to the patient only as ordered by another clinician.
A radiologist interpreting an imaging study ordered by another clinician
© 2017 Vizient, Inc. and AAMC Page 43
2018 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 44
2018 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 45
Expansion of Medicare’s Diabetes Prevention Program
© 2017 Vizient, Inc. and AAMC Page 46
Medicare 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 47
MDPP’s Finalized Requirements
CMS Finalized Requirements Beneficiaries Eligibility
Effective date beginning April 1, 2018 (instead of January 1, 2018)
Services begin April 1, 2018 Providers can begin enrolling January 1, 2018
12-month program using the CDC-approved DPP curriculum
Beneficiaries can only enroll in MDPP once Beneficiaries who complete the 12 month program who
achieve and maintain required weight loss can be eligible for up to one year of monthly maintenance sessions as long as weight loss is maintained
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
Pre-diabetic patient having a body mass index (BMI) of 25 or greater (BMI of 23 for Asian beneficiaries)
Following blood levels: Hemoglobin A1c test with a value of 5.7-6.4
percent or; a fasting plasma glucose of 110-125 mg/dL
within last 12 months or; 2-hour plasma glucose of 140-199 mg/dL after
the 75 gram oral glucose tolerance test No previous diagnosis of diabetes (applies only at time
of the first core session)
© 2017 Vizient, Inc. and AAMC Page 48
MDPP Reimbursement
• Number of
Sessions Attended
• Achievement and Maintenance of Min. Weight Loss
Two Factors
© 2017 Vizient, Inc. and AAMC Page 49
MDPP ReimbursementPerformance Goal Payment Per Beneficiary
(with min. weight loss)Payment Per Beneficiary (without min. weight loss)
1 session attended $25
4 sessions attended $50
9 sessions attended $90
2 sessions attended in 1st
core maintenance session interval (months 7-9)
$60 $15
Weight loss of 5%achieved
$160 $0
Advanced weight loss of 9% achieved
$25 $0
Max Total Performancepayment
$670 $195
© 2017 Vizient, Inc. and AAMC Page 50
Diabetes 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 51
Medicare Shared Savings Program Changes
Revises assignment methodology for
assigning Medicare FFS beneficiaries to an ACO based on utilization of services furnished by
rural health clinics and federally qualified health
care centers.
Adds 3 new chronic care management codes and
behavioral health integration codes to
definition of primary care services
Reduces burden for submitting an initial
Shared Savings Program application and
application for use of SNF 3 day waiver
Makes changes for consistency with the
MIPS program reporting under MACRA
© 2017 Vizient, Inc. and AAMC Page 52
Resource 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 Schedulehttps://www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2017-Fact-Sheet-items/2017-11-02.html
AAMC Webpage: Physician Payment and Qualityhttps://www.aamc.org/initiatives/patientcare/patientcarequality/311244/physicianpaymentandquality.html
© 2017 Vizient, Inc. and AAMC Page 53
Questions 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
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