The AMA is concerned that this task order will merely scratch the surface of developing the necessary education programs for physicians. We remain convinced that for the good of patients, physicians, and the Medicare program, HCFA must recognize physician education as a priority. The agency should implement policies that reflect physician education as a cornerstone of its program integrity efforts. Individualized physician education should be intertwined into the carriers' prepayment review and post payment audit activities. The AMA is worried that other task orders do not recognize organized medicine as a critical stakeholder.
Physicians are integral to program integrity efforts.
They frequently are the ones who are bearing the brunt of the increased compliance requirements and paperwork burdens. It is important for MIP contractors to work with and get feedback from not only potential law enforcement partners but also the medical community. HCFA should ensure that MIP contracts are well grounded not only from a law enforcement standpoint but also in the real life practice of medicine and patient care. Physicians are already spending too much time away from their patients to comply with the more than 100,000 pages of federal rules applicable to the Medicare program. The task orders do not clearly articulate the criteria for evaluating the MIP contractors.