The 2020 Medicare Physician Fee Schedule will implement the final phase of the California geographic payment fix, which is transitioning California payment localities to Metropolitan Statistical Areas (MSAs). The California Medical Association (CMA) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed fee schedule, expressing the association’s extreme concern with the errors, inaccuracies and unprecedented lack of transparency related to the national geographic practice cost index (GPCI), particularly the rent and wage indices, and the payment area update in California.  

CMA has a long history of advocating for Medicare geographic payment accuracy with consistent methodologies and transparent data sources. We have successfully partnered with CMS, MedPAC and Congress to improve the accuracy of Medicare geographic payments. 

When the 2020 proposed physician fee schedule rule was released, CMA’s analysis uncovered serious errors in the transition of the California payment localities to MSAs that were implemented inconsistent with the law. We also found major discrepancies in the national practice expense rent indices, and question the change in methodology for calculation of the professional work, wage and professional service indices.

CMA is also very concerned that there is an unprecedented lack of transparency in the data sources, which make it extremely difficult to understand the methods used by CMS and verify the accuracy of the payments.

CMA is urging CMS to immediately remedy these egregious GPCI-related errors and renotice the corrections in the Federal Register for verification prior to adoption of the final rule. 

For more information, see CMA’s comments.