The Centers for Medicare and Medicaid Services (CMS) left many physicians feeling exposed as data on individual payments were released to major newspapers ahead of the agency posting the data on its website.

Newspapers and media outlets had enough time ahead of the official release of the data to conduct some preliminary analysis and create reader-friendly search tools online. Medical groups and individual physician practices did not have such advance access and were left racing to review their own data ahead of any inquiries from the media. (Click here for the CMS data on individual Medicare physician payments.)

The American Medical Association (AMA) was opposed to the release of the data, especially since physicians did not have the opportunity to review the data ahead of its release and had no mechanism for correcting inaccuracies. However, it elected not to fight the release of the data. Instead, it worked to educate the media and the public on the limitations of individual physician payment data. According to the AMA guidance these include:

1. Data errors. For example, if a physician’s specialty is reported incorrectly, fhe or she could look like an outlier compared to others in the specialty.
2. Lack of care quality information.
3. Misleading information on number of services. For example, residents and other health care professionals under a physician’s supervision can file claims under his or her National Provider Identifier making it look as if one individual is performing an unusually high number of services. 
4. Differences between billed charges and actual payments. CMS will report both the physician’s billed charge and the actual amount paid, which is set by the Medicare Physician Fee Schedule. Payments generally are much less than the billed amount.
5. No data representing the unique makeup of an individual physician’s patient population. The data doesn't include services related to non-Medicare patients or account for the complexities of the physician’s patient population.
6. Variation in payment amounts based on place of service. A physician primarily seeing patients in a hospital may look like he or she is overcharging compared to a physician who primarily sees patients in the outpatient setting.
7. Overly generic specialty descriptions that hinder clear comparisons of physicians. For example, two physicians listed in the same specialty may actually have very different practice types.
8. No data on important factors such as patient mix, patient demographics, or drug and supply costs.
9. Variation in coding and billing rules over time and across regions. Changes to Medicare’s coding and billing rules need to be taken into account in any analysis because these rules frequently change over time and across different parts of the country.

"The American Medical Association (AMA) is committed to transparency and the availability of information for patients to make informed decisions about their medical care," said AMA President Ardis Dee Hoven, M.D., in a statement released Wednesday morning. "We believe that the broad data dump today by CMS has significant short-comings regarding the accuracy and value of the medical services rendered by physicians. Releasing the data without context will likely lead to inaccuracies, misinterpretations, false conclusions and other unintended consequences."