Access & Reimbursement

Fair and adequate reimbursement for infectious diseases physicians is a key IDSA policy priority. The Society also advocates for access to appropriate treatments for patients with serious infections and for medical liability reform. IDSA’s positions on specific reimbursement and access issues that impact the practice of infectious diseases and Advocacy Alerts to key policy priorities are provided below.

Contact your Congressional representative through our Advocacy Center to support fair and adequate reimbursement for infectious diseases physicians.

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Medicare Evidence Development & Coverage Advisory Committee (MEDCAC)

Medicare Payment Advisory Commission (MedPAC)

IDSA Comments on Medicare Physician Fee Schedule

9/13/2021

IDSA submits comments to CMS advocating for better pay for ID physicians and provides comments on the Quality Payment Program and other issues of importance to ID physicians.

IDSA Signs On to AMA Letter to CMS on MIPS Cost Measures

4/13/2021

IDSA signs on the the American Medical Associations comment letter to the Centers for Medicare and Medicaid Services regarding the release the 2018, 2019, and 2020 MIPS cost measures benchmarks and making cost measure benchmarks and patient attribution information available on a rolling, close to real-time basis during the 2021 performance year and future performance periods.

IDSA Comments on CY2021 Coding and Payment for Personal Protective Equipment Interim Final Rule Policy

1/28/2021

IDSA submitted comments to the Centers for Medicare and Medicaid Services on the CY2021 Coding and Payment for Personal Protective Equipment (PPE) Interim Final Rule Policy.

IDSA Signs On to AMA Comment Letter to CMS on MIPS Value Pathway

3/5/2021

IDSA signs on to the American Medical Association comment letter to the Centers for Medicare and Medicaid Services on recommendations to ensure the Merit-based Incentive Payment System (MIPS) Value Pathway (MVP) is successfully implemented.

IDSA Letter to Show Support and Offer Recommendations on New Legislation (PDF)

11/9/2020

IDSA expresses support for the Holding Providers Harmless From Medicare Cuts During COVID–19 Act, and offer recommendations on the 2021 Medicare Physician Fee Schedule Rule.

IDSA Comments on CY2021 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule

10/1/2020

IDSA submitted comments to the Centers for Medicare and Medicaid Services on the CY2021 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule.

IDSA Signs On to the Cognitive Care Alliance CY2021 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule Comment Letter

10/2/2020

IDSA signs on to the Cognitive Care Alliance CY2021 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule comment letter.

Medicare Hospital Conditions of Participation Revised to Include Antimicrobial Stewardship

1/22/2020

Effective March 30, 2020 Hospitals and Critical Access Hospitals that participate with the Medicare program will have to demonstrate the implementation and use of an antimicrobial stewardship program. IDSA provided comments to the Centers for Medicare & Medicaid staff regarding the implementation of the new Conditions of Participation for stewardship.

IDSA Letter to CMS Re Antibiotic Incentives (PDF)

11/1/2019

IDSA submitted recommendations to CMS to reform reimbursement to sustain the antibiotic market and support optimal antibiotic use.

IDSA Comments on CY2020 Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule

9/25/2019

IDSA submitted comments to the Centers for Medicare and Medicaid Services on the CY2020 for the Medicare Physician Fee Schedule and Quality Payment Program Proposed Rule.

IDSA Comments to CMS Re IPPS (PDF)

6/24/2019

IDSA submitted comments to the Centers for Medicare & Medicaid Services on the proposal in the FY 2020 Medicare Hospital Inpatient Prospective Payment System (IPPS) Proposed Rule to increase New Technology Add-On Payments (NTAP).

IDSA signs on to the AMA’s letter to Congress to propose changes to the MACRA legislation.

6/3/2019

IDSA signs on to the American Medical Association’s letter to urge Congress to simplify the current MIPS reporting methods and to develop more innovative payment models.

IDSA Comments to CMS Regarding CY2019 Home Health Final Rule (PDF)

12/28/2018

IDSA submitted comments to the Centers for Medicare and Medicaid Services Administrator on the proposed rule for the 2019 Home Health Prospective Payment Systems.

IDSA Comments to CMS Regarding CY2019 MPFS Final Rule (PDF)

12/28/2018

IDSA submitted comments to the Centers for Medicare and Medicaid Services on the proposed rule for the 2019 Physician Fee Schedule regarding changes to Evaluation and Management Services.

IDSA signs on to Cognitive Care Alliance Letter to CMS Administrator on PFS/QPP final rule (PDF)

12/19/2018

IDSA signs on to Cognitive Care Alliance Letter to Centers for Medicare & Medicaid Services on the proposed rule for the 2019 Physician Fee Schedule/ Quality Payment Program.

IDSA Comments to CMS Regarding CY2019 QPP and PFS (PDF)

9/10/2018

IDSA submitted comments to the Centers for Medicare & Medicaid Services on the proposed rule for the 2019 Physician Fee Schedule.

IDSA Comments on Specific E/M Proposals in the 2019 PFS Proposed Rule (PDF)

8/30/2018

IDSA submitted comments to the Centers for Medicare & Medicaid Services on the proposed rule for the 2019 Physician Fee Schedule.

IDSA Comments to House E&C Subcommittee on Health Re MACRA and MIPS (PDF)

7/25/2018

IDSA comments to the House Energy & Commerce Committee Health Subcommittee on the hearing MARCA and MIPS: An Update on the Merit-Based Incentive Payment Systems, outlining the important role of ID physicians and recommendations to MIPS related to antibiotic resistance, stewardship, and the underlying ID physician compensation issue.

IDSA Urges CMS to Reduce 2018 MIPS Quality Reporting Period (PDF)

4/16/2018

In coalition with other medical specialty societies, IDSA asks the Centers for Medicare & Medicaid Services (CMS) to reduce the 2018 Merit-based Incentive Payment System (MIPS) quality measure reporting period from a calendar year to a minimum of 90 consecutive days due to the lack of timely and direct notification by CMS on the MIPS eligibility status of physicians as well as delays in updating the Quality Payment Program (QPP) website with 2018 QPP reporting information.

Physician Group Letter to HHS on Drug Pricing Proposals (PDF)

3/13/2018

Physician Group Letter to HHS on Drug Pricing Proposals

IDSA Comments on the 2018 Medicare Final Rule for the Quality Payment Program (PDF)

1/2/2018

The Infectious Diseases Society of America (IDSA) appreciates the opportunity to provide comments on the 2018 final rule of the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Programs, collectively known as the Quality Payment Program (QPP).

IDSA Comments on the CY2018 Medicare Physician Fee Schedule Proposed Rule (PDF)

9/11/2017

IDSA provides comments on the Medicare Physician Fee Schedule (MPFS) proposed rule for calendar year 2018.

IDSA Comments on the 2018 Medicare Proposed Rule for the Quality Payment Program (PDF)

8/21/2017

IDSA provides comments on the 2018 Medicare Proposed Rule for the Merit-based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) Incentive Programs, collectively known as the Quality Payment Program (QPP).

Episode Group Comment Letter Draft (PDF)

4/24/2017

Episode-based Cost Measure Development for the Quality Payment Program - Comment Letter

Bicillin L-A and Penicillin G Procaine Shortage Update (PDF)

4/17/2017

Update from the CDC Division of STD Prevention regarding the ongoing shortage of Penicillin G benzathine (Bicillin L-A) and Penicillin G procaine in the U.S.

AMA Sign-on Letter to CMS & ONC (PDF)

2/27/2017

IDSA signs on to AMA letter addressed to CMS and ONC calling for a delay in implementing 2015 Edition certified electronic health record technology (CEHRT).

IDSA Joins Letter to President-elect on Need for Improved Reimbursement (PDF)

12/16/2016

Cognitive specialty groups, including IDSA, wrote to President-elect Trump asking that research move forward to improve the reimbursement of evaluation and management services through Medicare.

IDSA Comments on the Medicare Final Rule for the Quality Payment Program (PDF)

12/16/2016

IDSA provides comments on the Medicare Final Rule for the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Programs, collectively known as the Quality Payment Program (QPP). Specifically, IDSA provides further specifics on improvement activities (IAs), virtual groups, hospital-based physicians, and quality and cost measurement int he Medicare QPP.

IDSA Jointly Provides Comments to CMS on the Sepsis National Hospital Inpatient Quality Measure (PDF)

10/12/2016

In collaboration with the American College of Emergency Physicians, the Society of Critical Care Medicine, and the Society of Hospital Medicine, IDSA jointly submitted a letter to the Center for Medicare and Medicaid Services (CMS) expressing our concerns with the antibiotics listed for the Sepsis National Hospital Inpatient Quality Measure (SEP-1) and provided recommendations towards addressing the issue.

IDSA Comments on the CY2017 Medicare Physician Fee Schedule Proposed Rule (PDF)

9/6/2016

IDSA provides comments on the Medicare Physician Fee Schedule (MPFS) Proposed Rule for calendar year 2017 regarding medicare telehealth services, non-face-to-face prolonged evaluation and management (E/M) services, improving payment accuracy for primary care, care management, and patient centered services, valuation of the global surgery codes, and proposed expansion of the diabetes prevention program (DPP) model.

IDSA Jointly Comments on the CY2017 Medicare Physician Fee Schedule Proposed Rule (PDF)

9/6/2016

As a member of the Cognitive Care Alliance, IDSA jointly comments on the CY2017 Physician Fee Schedule Propose Rule. Specifically, comments are provided on the collection of data on resources used in furnishing global services as well as improving payment accuracy for primary care, care management, and patient centered services.

IDSA Comments on the Medicare and Medicaid Programs, Hospital and Critical Access Hospital Changes to Promote Innovation, Flexibility, and Improvement in Patient Care (PDF)

8/15/2016

IDSA provides comments on the proposed regulation regarding Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. The comment letter stresses the importance of infectious diseases physician leadership in infection control and prevention programs as well as strongly supporting proposed changes relating to adherence to national infection prevention and control guidelines, organizational accountability for healthcare acquired infections (HAIs), responsibilities of the infection preventionist/infection control professional, and medical record services.

IDSA Jointly Comments on Medicare and Medicaid Programs' Condition of Participation for Antimicrobial Stewardship (PDF)

8/15/2016

IDSA, in collaboration with SHEA, jointly provides comments on the proposed rule regarding Medicare and Medicaid Programs; Hospital and Critical Access Hospital (CAH) Changes to Promote Innovation, Flexibility, and Improvement in Patient Care. The comment letter stresses the importance of antimicrobial stewardship programs (ASPs) and IDSA and SHEA's strong support of the proposal to require ASPs at acute care and critical access hospitals (CAHs). Furthermore, we provide comments on leadership of ASPs, ASP leadership's separate designation from infection preventionist/infection control professionals, ASPs measures of success, and tele-stewardship models to serve CAHs.

IDSA Jointly Comments on the Veterans Health Administration's Advanced Practice Registered Nurses Proposed Rule (PDF)

7/22/2016

In cooperation with many physician organizations representing national specialty and state medical societies, IDSA jointly provides comments on the Veterans Health Administration's (VHA) Advanced Practice Registered Nurses (APRNs) Proposed Rule. The comments strongly oppose the proposed rule and urge the VHA to consider policy alternatives that prioritize team-based care rather than independent nursing practice.

IDSA Recommendations to Senate Finance Committee on MACRA (PDF)

7/12/2016

IDSA recommendations to the Senate Finance Committee for the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, including the need for new infectious diseases (ID) quality measures and ways to better align new physician quality improvement programs with antibiotic stewardship and public health emergency preparedness. IDSA also highlighted the current undervaluation of the ID specialty and the steep decline in the number of physicians pursuing ID.

IDSA Comments on the Merit Based Incentive Payment System and Alternative Payment Model Incentive Under the Physician Fee Schedule (PDF)

6/27/2016

IDSA provides comments on the Merit Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule regarding the impact of the new quality payment program on the specialty of infectious diseases. Specifically, comments are provided on quality measures under MIPS, hospital-based physicians, development and implementation of quality measures, submission mechanisms, reporting on outcomes and high priority measures, threshold for data completeness, clarification on scoring of quality measurement under MIPS, specialty-specific measures, quality clinical data registries (QCDRs), virtual groups, quality performance period, and APMs. Furthermore, IDSA provides suggestions for clinical practice improvement activities (CPIAs) under MIPS that include antimicrobial stewardship programs, emergency response and preparedness, telehealth services, and CME.

IDSA Jointly Comments on the MACRA Proposed Rule (PDF)

6/25/2016

IDSA jointly comments on the implementation of the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) under the Medicare Access and CHIP Reauthorization Act (MACRA). The comments seeks to simplify the proposed MIPS program to ensure that is facilitates meaningful opportunities for performance improvement while decreasing administrative and compliance burdens, provide a more robust APM pathway that can support physicians who want to make the transition to new delivery and payment models, and accommodate the needs of physicians in rural, solo, or small practices in order to enhance their opportunities for success and avoid unintended consequences.

IDSA Comments on the FY 2017 Inpatient Prospective Payment System Proposed Rule (PDF)

6/7/2016

IDSA provides comments on the FY 2017 Inpatient Prospective Payment System (IPPS) proposed rule specifically regarding the Inpatient Quality Reporting (IQR) Program, sociodemographic (SDS) factors for quality measures, and the National Healthcare Safety Network (NHSN) Antimicrobial Use measure.

IDSA Provides Comments on the RFI Assessing Interoperability for the MACRA (PDF)

6/3/2016

IDSA jointly provides comments on the request for information (RFI) assessing interoperability for the Medicare Access and CHIP Reauthorization Act (MACRA). The comment letter express concern with the proposed use of current Meaningful Use (MU) program measures in the new Advancing Care Information (ACI) category within MACRA and recommends that the Office of the National Coordinator for Health Information Technology (ONC) and the Center for Medicare and Medicaid Services (CMS) collaboratively develop a list of proxy measures or metrics to capture valid, useful interoperability.

IDSA provides comment on the FDA draft guidance for use of FMT to treat recurrent CDI (PDF)

5/26/2016

IDSA responds the latest draft guidance issued by the FDA related to the use of FMT to treat recurrent CDI. In this draft guidance, the FDA has outlined its enforcement policy regarding IND requirements for FMT when use to treat RCDI. IDSA advocates for a finalized guidance that does not impose administrative burden on physicians who treat patients with RCDI with FMT.

IDSA Joins Other Medical Societies to Raise Awareness of Physicians’ Concerns Regarding the Implementation of MACRA (PDF)

4/18/2016

IDSA jointly expresses concerns regarding the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). More specifically, comments are provided on the following overarching issues, ensuring that the implementation of MACRA does not disrupt the positive effect Alternative Payment Models (APMs) are having on beneficiaries' health in the public and private sector, the need for a clear pathway for private sector models to meet the threshold for qualifying APMs under MACRA, virtual groups in the Merit-Based Incentive Payment System (MIPS) should be defined to help small, independent physician practices remain viable, and existing clinical quality improvement activities should satisfactorily meet MIPS requirements.

IDSA Comments on 2016 Physician Quality Reporting System Feedback and Informal Review Processes (PDF)

2/9/2016

IDSA has joined the AMA and 45 other medical societies in expressing concerns with the Centers for Medicare and Medicaid Services' inadequate feedback and informal review request processes. Specifically, the societies state issues with incomplete and inconsistent feedback, the lack of recourse for vendor transmission issues, inadequate assistance from QualityNet Help Desk, and the faulty informal review process.

IDSA Letter to House Oversight Committee on Drug Pricing (PDF)

1/21/2016

In advance of the House Government Oversight and Reform Committee hearing “Developments in the Prescription Drug Market,” IDSA sent a letter to Committee leaders related to broader issues regarding access to existing and new therapies for preventing and treating infectious diseases.

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