This Weekend Is Your Last Chance to Tell CMS “No!” to Separate and Discriminatory Podiatric E/M Codes | News | APMA
This Weekend Is Your Last Chance to Tell CMS “No!” to Separate and Discriminatory Podiatric E/M Codes

September 6, 2018

Advocacy written in red across a folded newspaper.

Update: CMS is closing the opportunity to comment on its proposed changes for the 2019 Medicare Physician Fee Schedule this coming Monday, September 10. As a reminder, included among many proposed changes, CMS also included a proposal to require only podiatric physicians to use a separate set of E/M codes, which would pay significantly less. If you haven’t already utilized APMA’s eAdvocacy portal to express your opposition to this punitive proposal, we urge you to do so now. Every voice counts; it only takes a few minutes to submit these comments to help your profession!

You only have until September 10 to tell CMS that you oppose separate E/M codes for podiatrists that reimburse less. APMA launched its CMS eAdvocacy campaign on July 30. Via eAdvocacy, you can submit letters to CMS and your members of Congress. Your family members, friends, and patients can also submit a letter to CMS via eAdvocacy, as well.

To date, over 7,000 letters have been sent to CMS from DPMs and non-DPMs combined, and more than 2,900 DPMs have sent letters to their members of Congress. If you haven’t yet sent letters to CMS or your congressional members, we urge you to do so now! It only takes a few moments, and it would send a strong message to Congress to have every DPM send a letter.

You might be wondering, “What else is APMA doing to stop CMS from finalizing this discriminatory and punitive proposal?” Most recently, on August 23, APMA submitted a high-level comment letter to CMS to register its strong opposition to CMS’ proposal to separate DPMs from all other Medicare providers. We will be submitting an additional comprehensive formal comment letter that addresses the E/M proposals in depth along with the other issues in the 2019 Medicare Physician Fee Schedule Proposed Rule.

APMA has also had very productive conversations with medical societies and other organizations. It has shared with them the association’s language to oppose the podiatry-specific E/M Codes. While these discussions are ongoing, several organizations have included opposition to the podiatry E/M codes in their comment drafts, and several others have indicated they have a placeholder in their comment draft letters to address opposition to the podiatry E/M codes.

APMA has signed on to coalition letters calling CMS not to finalize any E/M proposals this year and instead engage with stakeholders, including letters from the American Medical Association, the American Geriatric Society (AGS), and the American College of Rheumatology.

APMA is also participating as a member of the AGS-led coalition opposing the changes to the E/M codes. This coalition includes more than 40 medical and patient advocacy associations. We have also reached out to MedPAC. APMA has a face-to-face meeting with CMS Deputy Administrator Demetrios Kouzoukas and other CMS officials later this week and a meeting scheduled with the White House Office of Management of Budget Health Official Joe Grogan on September 4.

Face-to-face congressional meetings detailed in last week’s update have proven to be fruitful, as several members of Congress have contacted CMS on our behalf: Brad Wenstrup, DPM (R-OH); Marsha Blackburn (R-TN); Earl Blumenauer (D-OR); and Doris Matsui (D-CA) have drafted a congressional letter directed at CMS opposing the podiatry E/M codes, among other issues, and are asking their colleagues to sign on to the letter to gain additional support. 

APMA recognizes and appreciates the efforts of members and state component leaders to ensure their representatives and leaders are aware of this issue and stand up against it. This is an all-hands-on-deck effort, and APMA appreciates the support from the many friends of podiatry who recognize the value of care provided by podiatrists.

For any questions about these efforts, contact the APMA Health Policy and Practice Department at

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