Medicare Physician Payment

Medicare Physician Payment / en Fri, 25 Apr 2025 20:19:56 -0500 Fri, 10 Jan 25 15:44:47 -0600 AHA urges MedPAC to update payments for hospitals, post-acute care and physicians /news/headline/2025-01-10-aha-urges-medpac-update-payments-hospitals-post-acute-care-and-physicians <div>The AHA today <a href="/2025-01-10-aha-comments-advance-medpac-january-2025-meeting" target="_blank">urged</a> the Medicare Payment Advisory Commission to update payment recommendations for hospitals, post-acute care facilities and physicians in advance of the commission's Jan. 16 public meeting. AHA urged MedPAC to issue a higher update than the current-law market basket update plus an additional 1% for the hospital inpatient and outpatient prospective payment systems.</div><div>The AHA disagreed with a draft recommendation from the commission in December that would reduce fiscal year 2026 inpatient rehabilitation facility PPS payments by 7%. Instead, the AHA urged MedPAC to support a current-law market-basket update for IRFs. The AHA made similar requests for payments to skilled nursing facilities and home health agencies.</div><div>MedPAC was also urged by the AHA to recommend a higher update to physician reimbursement that would more fully account for impacts from inflation and physician fee schedule cuts.&nbsp;</div> Fri, 10 Jan 2025 15:44:47 -0600 Medicare Physician Payment MedPAC discusses 2026 draft payment update recommendations /news/headline/2024-12-13-medpac-discusses-2026-draft-payment-update-recommendations <div>The Medicare Payment Advisory Commission Dec. 12 and 13 discussed draft payment update recommendations for 2026, which the commission will vote on in January. The draft recommendations call for Congress to update Medicare payment rates for hospital inpatient and outpatient services by the current law amount plus 1% and transition to a safety-net index policy to distribute an additional $4 billion to safety-net hospitals.&nbsp;&nbsp;</div><div>They also propose that Congress update 2026 Medicare base payments for physicians and other health professional services by the projected increase in the Medicare Economic Index minus 1% and enact safety net add-on payments for services delivered to low-income Medicare beneficiaries. In addition, the commission proposes to reduce the 2026 payment rate for inpatient rehabilitation facilities by 7%, home health agencies by 7%, and skilled nursing facilities by 3%.</div> Fri, 13 Dec 2024 13:25:39 -0600 Medicare Physician Payment AHA supports physician reimbursement, alternative payment model incentives in comments to MedPAC /news/headline/2024-12-09-aha-supports-physician-reimbursement-alternative-payment-model-incentives-comments-medpac In <a href=/lettercomment/2024-12-09-aha-comments-medpac-re-physician-fee-schedule-payments-apm-incentives-and-medicare-advantage-network)" target="_blank">comments</a> Dec. 9 to the Medicare Payment Advisory Commission, the AHA shared its views on physician fee schedule payments, advanced alternative payment model incentives and Medicare Advantage network adequacy. The AHA expressed support for updates to physician reimbursement tied to the Medicare Economic Index, but said that the discussed factor of MEI minus one is not nearly sufficient to make up for existing shortcomings in physician reimbursement. The AHA opposed penalizing facility-based providers by reducing their reimbursement rates.&nbsp; &nbsp; "Doing so is not only inappropriate, but also would create an even greater incentive for physicians to seek out employment from other entities, such as private equity firms and health insurers (which have acquired the vast majority of physician practices during the last five years)," AHA wrote.&nbsp; &nbsp; The AHA also expressed support for A-APM payments and urged MedPAC to explore the impact of inadequate MA post-acute care network requirements on beneficiaries’ access to care.&nbsp; Mon, 09 Dec 2024 15:50:10 -0600 Medicare Physician Payment Medicare Physician Fee Schedule CY 2025 Final Rule <div class="container"><div class="row"><div class="col-md-8">The Centers for Medicare &amp; Medicaid Services (CMS) Nov. 1 issued a&nbsp;<a href="https://www.federalregister.gov/public-inspection/2024-25382/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule">final rule</a> that updates physician fee schedule (PFS) payments for calendar year (CY) 2025. The rule also modifies policies related to the Medicare Shared Savings Program (MSSP) and the Quality Payment Program (QPP), both of which were created by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. Additionally, the rule changes policies related to the Medicare Prescription Drug Inflation Rebate Program and Medicare Parts A and B overpayment provisions of the Affordable Care Act.<div class="panel module-typeC"><div class="panel-heading"><h2>Key Highlights</h2>CMS’ policies will:<ul><li>Reduce the PFS conversion factor by 2.8% to $32.35 in CY 2025 as compared to $33.29 in CY 2024.</li><li>Delay implementation of the rebased and revised Medicare Economic Index (MEI) until future rulemaking.</li><li>Extend certain telehealth waivers through 2025, including the waiver allowing for reporting of enrolled practice addresses instead of home addresses when providers perform services from their homes.</li><li>Establish new payments for practitioners offering certain behavioral health crisis services and digital mental health treatment as well as for interprofessional consultations by non-physician mental health practitioners.</li><li>Finalize several policies regarding the Medicare Part B and Part D Drug Inflation Rebate Programs, including to exclude drugs purchased under the 340B Drug Pricing Program.</li><li>Revise the data reporting period and phase-in of payment reductions for clinical laboratory tests under the Clinical Laboratory Fee Schedule (CLFS) to conform with statutory changes.</li><li>Suspend, under certain circumstances, the deadline for reporting and returning Medicare Parts A and B overpayments for up to 180 days to allow time for providers to investigate and calculate overpayment.</li><li>Exclude suspected anomalous spending from financial calculations for the MSSP.</li><li>Require MSSP accountable care organizations (ACOs) to report a new Advanced Alternative Payment Model (APM) Pathway Plus measure set.</li><li>Add six new Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) for CY 2025.</li></ul></div></div><h2>AHA TAKE</h2>The AHA is concerned that despite mounting physician shortages, rising inflation and higher input costs, CMS continues to cut the physician reimbursement conversion factor. Indeed, this latest cut comes on top of two decades of decreases in physician payments.&nbsp;Repeated reductions in physician reimbursement&nbsp;pose significant threats to patient access and provider financial stability, particularly for underserved communities.The AHA is also disappointed that the agency did not provide additional flexibilities for good-faith investigations of Medicare Parts A and B overpayments, which may require time beyond six months. While we appreciate that CMS has recognized that providers need time to conduct appropriate investigations of potential overpayments, the 180-day window for investigations may not be sufficient for large health care providers or complex cases spanning multiple sites or calendar years and risks generating new liability for providers investigating potential overpayments in good faith.We thank CMS for extending certain regulatory telehealth flexibilities through 2025. However, we urge CMS to work with Congress to also extend critical statutory waivers. Without action, we risk a telehealth “cliff” that will negatively impact patient access in all communities.Finally, we are also pleased that CMS finalized policies to exclude suspected anomalous spending from financial calculations for MSSP, which will avoid penalizing accountable care organizations for such actions outside their control.<a>WHAT YOU CAN DO</a><ul><li>Share this advisory with your chief medical officer, chief financial officer and other members of your senior management team, as well as key physician and nurse leaders.</li><li>Assess the impact of the final rule payment and quality changes on your Medicare revenue and operations.</li></ul>View the detailed Regulatory Advisory below.</div><div class="col-md-4"><a href="/system/files/media/file/2024/11/medicare-physician-fee-schedule-cy-2025-final-rule-advisory-11-21-2024.pdf"><img src="/sites/default/files/inline-images/cover-medicare-physician-fee-schedule-cy-2025-final-rule-advisory-11-21-2024.pdf_.png" data-entity-uuid="52a8a47b-bca5-4a11-9cbd-fa46c0998248" data-entity-type="file" alt="Regulatory Advisory Cover Image" width="679" height="878"></a></div></div></div> Thu, 21 Nov 2024 14:13:38 -0600 Medicare Physician Payment AHA/CMS Webinar: Managed Care State Directed Payments and Health Care-Related Taxes In this member-only webinar, Centers for Medicare &amp; Medicaid policy experts John Giles (Director, Managed Care group) and Rory Howe (Director, Financial Management Group) discussed the final rules governing State Directed Payment (SDP) programs included in the Medicaid Managed Care Access, Finance, and Quality rule. The final rule made substantial changes to SDP programs intended to strengthen fiscal and program integrity, and enhance evaluation and reporting related to SDPs.Members can view the <a href="https://aha-org.zoom.us/rec/share/JUA8c8e95Pk_X0dQbjnh7DEApSLDdyP-72onL17tKM1zxsUw5W6qFpTZWRO6sK0J.xa1wHpZXov52stB8?startTime=1723741211000" download="file" target="_blank">recording of the session </a>and download slides below for further review. Fri, 16 Aug 2024 10:35:36 -0500 Medicare Physician Payment AHA files amicus brief supporting reviewability of certain CMS determinations /news/headline/2024-07-30-aha-files-amicus-brief-supporting-reviewability-certain-cms-determinations The AHA along with the Federation of ��s, America’s Essential Hospitals and the Association of American Medical Colleges July 29 filed an <a href="/amicus-brief/2024-07-30-amicus-brief-aha-others-file-amicus-brief-challenging-reviewability-certain-cms-determinations">amicus brief</a> in the U.S. Court of Appeals for the District of Columbia in support of hospitals’ continued right to seek immediate review of any Centers for Medicare &amp; Medicaid Services determination that could impact Medicare payments for providers. These determinations include those made under CMS’ disproportionate share hospital formula, which can have profound impacts on hospitals’ Medicare payment amounts even with minimal adjustments, and for which a months- or yearslong process to correct mistakes could have substantial and even irreparable consequences. &nbsp; &nbsp; Congress granted providers the ability to immediately challenge final determinations governing future payments when it enacted Medicare’s current prospective payment system, but CMS has since sought to arbitrarily narrow the category of determinations considered final, effectively insulating its decision making from review. As the brief makes clear, this effort by the government is untenable for hospitals. "Hospitals seeking to preserve their rights in the face of the government’s indeterminate reviewability test should not be forced to risk violating agency rules or be left relying on administrative grace," the brief states. "They should be able to take a statutory provision specifically designed to make immediate review broadly available at its word."&nbsp; &nbsp; The AHA, Federation, AEH and AAMC urged the D.C. Circuit to consider the vast potential consequences of the government’s shift for American hospitals both in the DSH context and beyond it. "At minimum, its approach compounds the complexity of an already-byzantine administrative apparatus and needlessly increases uncertainty," the brief notes. "Congress did not intend any of this. It enacted a simple provision that broadly allows hospitals to seek immediate review of any final CMS determination that reduces the payment amounts they will receive — including the DSH adjustment. This Court should give effect to Congress’s judgment and affirm." Tue, 30 Jul 2024 15:11:53 -0500 Medicare Physician Payment Speaking Up for Priorities That Will Help Hospitals Advance Health for Patients and Communities /news/perspective/2024-07-26-speaking-priorities-will-help-hospitals-advance-health-patients-and-communities It’s an understatement to say everything on the national political scene is both unprecedented and unpredictable these days.To state the obvious, there will be an election in about 100 days. And regardless of the outcome, it will be followed by a lame-duck session of Congress where there will be several must-do items — including funding the government — which becomes the legislative platform for a variety of issues, including critical ones impacting hospitals that need to be addressed before the end of the year.That’s why it’s so important to use this August recess that begins next week as an opportunity to engage senators and representatives while they are back home. More than ever, it is critical for federal lawmakers to understand the challenges hospitals and health systems face . . . and what’s at stake for access to care for the patients and communities they represent.Moreover, it is a terrific chance for our field to ensure lawmakers gain firsthand appreciation for all of the innovative and community-supportive things you are doing to improve access, enhance the patient care experience and continue to deliver a level of care that is top-notch.After all, our patients, their families and our team members are all their constituents. And as a practical matter, politicians listen most closely during an election year. They need to know that <a href="https://wecarewevote.aha.org/" target="_blank" we="" vote="">we care</a>, and <a href="https://app6.vocusgr.com/WebPublish/controller.aspx?SiteName=AHAPAC&amp;Definition=Contribute&amp;SV_Section=Contribute" target="_blank" title="Elections Matter! Join AHAPAC today.">we vote</a>.Some of the “must do” messages we need to deliver now include:We need to continue extending key rural programs that expire at the end of year like the Medicare dependent hospital program and the low-volume adjustment.We need to extend telehealth and hospital-at-home programs as these innovative efforts, which were adopted to help us manage the COVID-19 pandemic, have expanded access for millions of Americans and allowed patients to receive high-quality care more conveniently.We need to make sure that payment cuts for hospital services — like those so-called site-neutral adjustments — that appropriately provide a differential for hospital outpatient services are not used as an offset or to fund other programs.We need to continue to prevent Medicaid disproportionate share hospital cuts from kicking in next year that threaten essential financial assistance to hospitals that care for our nation’s most vulnerable populations — children, impoverished, disabled and elderly individuals.At the same time, the proposed Medicare payment reductions for physician services will need to be addressed.Of course, should the congressional “scope of work” widen beyond issues that are calendar driven, there are many other issues where we want to enlist lawmakers’ support and lay the groundwork for action next year. Among those that we have worked to gain the most attention right now are passage of the bipartisan Safety from Violence for Healthcare Employees Act (SAVE) Act, which would provide federal protections from workplace violence for hospital workers; holding commercial insurance companies accountable for practices that delay, deny and disrupt care; and working to bolster support for cybersecurity efforts.Next week, you’ll receive an Action Alert highlighting tools and resources to assist in your advocacy and you can visit our <a href="/advocacy/action-center">Action Center</a> webpage for the latest information.We may be living in unpredictable times, but one thing that is predictable — and will never change — is that hospitals will always be a source of hope and healing.We will always be focused on promoting wellness as well as caring for the sick and injured. And we will always be cornerstones of the communities we serve as we work together to advance health in America. Fri, 26 Jul 2024 08:57:04 -0500 Medicare Physician Payment AHA Letter to Senate Finance Committee on Medicare Part B White Paper /lettercomment/2024-06-17-aha-letter-senate-finance-committee-medicare-part-b-white-paper June 14, 2024<table><tbody><tr><td>The Honorable Ron Wyden Chairman Committee on Finance United States Senate 221 Dirksen Senate Office Building Washington, DC 20002</td><td>The Honorable Mike Crapo Ranking Member Committee on Finance United States Senate 239 Dirksen Senate Office Building Washington, DC 20510</td></tr></tbody></table>Wyden and Ranking Member Crapo:AHA’s nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the �� Association (AHA) writes to you to provide comment on the Senate Finance Committee white paper on Bolstering Chronic Care through Physician Payment, Current Challenges and Policy Options in Medicare Part B.We appreciate that the Senate Finance Committee has highlighted some of the pressing challenges confronting doctors reimbursed under the physician fee schedule (PFS). Indeed, current reimbursement for physicians is woefully inadequate and fails to account for inflation, which continues to outpace updates to reimbursement for services covered under the physician fee schedule. The latest Medicare Trustee’s Report indicates that physician reimbursement has dropped over 20% over the last 20 years when accounting for inflation. In addition, there is a widening gap between the conversion factor updates and Medicare Economic Index (a proxy measure for physician cost inflation).These reimbursement shortfalls to Medicare physician payment have come at a time of other headwinds. Hospitals and health systems are currently facing a national staffing emergency that could jeopardize access to high-quality, equitable care for patients and the communities they serve. Physician shortages are projected to exceed 86,000 physicians by 2036 according to the Association of American Medical Colleges. We have also seen how increased administrative burden is contributing to physician burnout and clinicians leaving the field. The aging beneficiary population is also increasing demand for services, while the supply of clinicians continue to decline. We appreciate the actions Congress has taken to support physicians by passing one-time adjustments to partially offset decreases to conversion factor. However, more sustainable solutions are needed to ensure that updates to the PFS more accurately reflect the cost of delivering services.Considering these challenges, the AHA supports the following legislative and regulatory changes to ensure more sustainable physician reimbursement and to facilitate transition to value-based care.<h2>Addressing Payment Update Adequacy and Sustainability</h2>Conversion Factor Updates. Portions of the bipartisan Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) were intended to fix some of the legacy issues with the historical sustainable growth rate (SGR), namely by replacing updates to the conversion factor which were tied to gross domestic product with updates that more accurately covered rising health care input costs through the Medicare Economic Index (MEI). However, inflation (as measured by the MEI) is growing faster than increases in PFS rates.From 2015-2019, MACRA provided a 0.5% increase in the conversion factor. However, starting in 2020 through 2025 there was a gap where MACRA programmed a 0% update to the conversion factor. The lack of a preset update combined with budget-neutral decrements has resulted in negative conversion factor updates and continued decreases in reimbursement despite rising input costs. This is because there is a compounding effect, whereby the cuts in one year mean that cuts in future years are already based on an artificially negative baseline and reimbursement exponentially spirals downward. To partially soften the cuts from the PFS after budget neutrality adjustments, Congress has acted to increase the conversion factor through one-time adjustments. For example, the Consolidated Appropriations Act (CAA) of 2023 provided partial relief for 2024 physician reimbursement rates through a one-time 1.25% increase. Even with the 1.25% adjustment, the conversion factor was still cut by 3.4% — meaning that reimbursement rates were still scheduled for a -3.4% reduction despite the one-time congressional add-on. As such, Congress again acted to increase the conversion factor by an additional 1.68%. This uncertainty has contributed to financial instability.The current conversion factor updates scheduled in MACRA are insufficient since they are scheduled to begin in 2026 and will only result in a 0.75% conversion factor update for qualifying advanced Alternative Payment Model (APM) participants and 0.25% for all other providers. This will be too little too late since again these will only partially offset the decrements that have occurred over the last 20 years. While the one-time conversion factor updates provided in the CCAs of 2022, 2023 and 2024 have provided needed relief in the interim, we encourage more sustainable, real-time approaches to updating the conversion factors in pace with inflation. Annual conversion factor updates should be made to reflect changes in input costs and inflation outside of budget neutrality.<h2>Incentivizing Participation in Alternative Payment Models</h2>Our members support the U.S. health care system moving toward the provision of more outcomes-based, coordinated care and are continuing to redesign delivery systems to increase value and better serve patients.Over the last 14 years, many of our hospital and health system members have participated in a variety of APMs. While the movement to value holds tremendous promise, the transition has been slower than anticipated and more needs to be done to drive long-term system transformations.Programmatic Design Principles. There are principles that we believe should guide the development of APM design that would make participation more attractive for potential participants. These include:<ul><li>Appropriate On-ramp and Glidepath to Risk. Model participants should have an adequate on-ramp and glidepath to transition to risk. They must have adequate time to implement care delivery changes (integrating new staff, changing clinical workflows, implementing new analytics tools, etc.) and review data prior to initiating the program.</li><li>Adequate Risk Adjustment. Models should include adequate risk adjustment methodologies to account for social needs and clinical complexity. This will ensure models do not inappropriately penalize participants treating the sickest, most complicated and underserved patients.</li><li>Voluntary Participation and Flexible Design. Model designs should be flexible, incorporating features such as voluntary participation, the ability to choose individual clinical episodes, the ability to add components/waivers and options for participants to leave the model(s).</li><li>Balanced Risk Versus Reward. Models should also balance the risk versus reward in a way that encourages providers to take on additional risk but does not penalize those that need additional time and experience before they can do so. A glidepath approach should be implemented, gradually migrating from upside only to downside risk.</li><li>Guardrails Ensure Long-term Performance Gains. Models should provide guardrails to ensure that participants do not have to compete against their own best performance and have incentives to remain in models for the long term.</li><li>Resources to Support Initial Investment. Upfront investment incentives should be provided to support organizations in their transition to value-based payment. For example, to be successful in such models, hospitals, health systems and provider groups must invest in additional staffing and infrastructure to support care delivery redesign and outcomes tracking.</li><li>Transparency. Models’ methodology, data and design elements should be transparently shared with all potential participants. Proposed changes should be vetted with stakeholders.</li><li>Adequate Model Duration. Models should be long enough in duration to truly support care delivery transformation and assess the impact on outcomes. Historically, models have been too short and/or have had multiple, significant design changes even within the designated duration, making it difficult for participants to self-evaluate and change course when necessary.</li><li>Timely Availability of Data. Model participants should have readily available, timely access to data about their patient populations. We would encourage the dedication of resources from the Centers for Medicare &amp; Medicaid Services (CMS) (staff and technology) to provide program participants with more complete data as close to real-time as possible.</li><li>Waivers to Address Barriers to Clinical Integration and Care Coordination. This entails waiving Medicare program regulations that frequently inhibit care coordination and work against participants’ efforts to ensure that care is provided in the right place at the right time.</li></ul>Extension of Advanced APM Incentive Payments. MACRA was also intended to support the transition to value-based care. MACRA provided advanced incentive payments (5%) for providers participating in advanced APMs through 2024. These payments were designed to assist with the provision of non-fee-for-service programs like meal delivery programs, transportation services, digital tools and care coordinators which promote population health, among other services.However, MACRA statute only provided the advanced APM bonuses through the calendar year (CY) 2024 payment period. We appreciate Congress acting through a provision in the CCA of 2023 to extend the advanced APM incentive payments at 3.5% for the CY 2025 payment period and again in the CAA of 2024 to extend through 2026 at 1.88%.While lower than the current 5% incentive payment rate, the incentive provides crucial resources. Because participation in the advanced APM program has fallen short of initial projections, spending on advanced APM bonuses has fallen well short of the amount the Congressional Budget Office projected when MACRA was originally scored. Repurposing the spending shortfall for APM bonuses in future years will serve to accelerate our shared goal of increasing APM adoption. We urge the extension of these incentive payments.Eliminate Low-Revenue/High-Revenue Qualifying Criteria. Congress also should urge CMS to eliminate its designation of ACOs as either low- or high-revenue. The agency has used this label as a proxy measure to, for example, determine if an physician-led to qualify for advance investment payments. Yet, there is no valid reason to conclude that this delineation, which measures an accountable care organization’s (ACO) amount of “captured” revenue, is an accurate or appropriate predictor of whether it treats an underserved region. In fact, analysis suggests that critical access hospitals, federally qualified health centers and rural health centers are predominantly classified as high-revenue. Further, both low- and high-revenue ACOs are working to address health equity as part of their care transformation work; assistance investing in these efforts would help across the board. We urge the removal of problematic high/low revenue thresholds that preclude rural and critical access hospitals from obtaining necessary resources for infrastructure investment.Support Investment in Resources for Rural Hospitals. Congress should encourage CMS to continue its investment of resources and infrastructure to support rural hospitals’ transition to APMs. According to a Government Accountability Office report, only 12% of eligible rural providers in 2019 participated in the advanced APM program; of those that participated, just 6% of rural providers participated in two or more advanced APMs, compared to 11% of those not in rural areas. These models are often not designed in ways that allow broad rural participation, and the AHA supports continued efforts to better support rural hospitals’ migration to advanced APM models. In particular, the AHA since 2021 has supported the establishment of a Rural Design Center within the Center for Medicare and Medicaid Innovation (CMMI), which would focus on smaller-scale initiatives to meet rural communities’ needs and encourage participation of rural hospitals and facility types. A Rural Design Center would help develop and increase the number of new rural-focused CMMI demonstrations, expand existing rural demonstrations and create separate rural tracks within new or existing CMMI models.In conclusion, to support the transition to value-based payment, the AHA urges Congress to extend APM incentive payments and for CMS to remove problematic high- and low-revenue thresholds that preclude rural and critical access hospitals from obtaining necessary resources for infrastructure investment. We support the Value in Health Care Act (H.R. 5013/S. 3503), which would extend incentive payments, remove revenue distinctions and improve financial benchmarks to ensure participants are not penalized for their success.Reducing Physician Reporting Burden Related to Merit-based Incentive Payment SystemImprove Measures in Merit-based Incentive Payment System (MIPS) Cost Category. The AHA believes that rigorously designed, clinically relevant cost measures can help provide insights into the value of care that clinicians deliver. At the same time, we have long been concerned with these measures’ limited actionability, extraordinary complexity, questionable reliability and rushed implementation. The cost measures currently in place have flawed metrics in evaluating performance and may result in rewards or penalties based on differences in patient population or statistical noise. Congress should encourage CMS to take steps to improve these cost measures by pursuing consensus-based entity endorsement of all cost measures used in the MIPS, re-examining the attribution methodologies and accounting for the influence of social risk factors beyond providers’ control in calculating performance where necessary and appropriate.<h2>Chronic Care Benefits in Fee-for-service</h2>Waiving Cost-sharing for Chronic Care Management. We endorse efforts to remove the patient cost-sharing obligations from the Chronic Care Management (CCM) code. Millions of chronically ill Medicare beneficiaries stand to benefit from the care coordination and care management services the code supports.Because CCM is a critical part of coordinated care, Medicare began reimbursing clinicians for primarily non-face-to-face chronic care management under a separate code in the 2015 Medicare PFS to manage chronic conditions and improve patients' health more effectively. Providers and care managers report many positive outcomes for beneficiaries who receive CCM services, including improved patient satisfaction and adherence to recommended therapies, improved clinician efficiency, and decreased hospitalizations and emergency department visits.&nbsp;However, creating a separate billable code created a beneficiary cost-sharing obligation for care management services. Under current policy, Medicare beneficiaries are subject to a 20% coinsurance requirement to receive the service. This cost-sharing requirement creates a barrier to care, as beneficiaries are not accustomed to cost-sharing for care management services. The latest data reveals that only 4% of Medicare beneficiaries potentially eligible for CCM received these services. That amounts to 882,000 out of a potential pool of 22.5 million eligible CCM beneficiaries. Removing the coinsurance payment requirement would facilitate more comprehensive management of chronic care conditions and improve the health of Medicare patients. Additionally, removing patient coinsurance may facilitate greater care coordination for underserved patient populations.<h2>Ensuring Beneficiaries’ Continued Access to Telehealth</h2>While we recognize that the committee did not have specific questions for consideration regarding continued access to telehealth, we echo the concerns expressed regarding a coverage cliff risk that could result if Congress does not act to extend critical waivers before the end of the year.The expansion of telehealth services during the public health emergency has transformed care delivery, expanded access for millions of Americans and increased convenience in caring for patients, especially those with transportation or mobility limitations. Given current health care challenges, including major clinician shortages, telehealth holds tremendous potential to leverage geographically dispersed provider capacity to support patient demand. We urge Congress to make these key telehealth flexibilities permanent before they expire on Dec. 31, 2024, and extend waivers for the hospital-at-home program.Specifically, we support the following.<ul><li>Permanently eliminating originating- and geographic-site restrictions, thus allowing telehealth visits to occur at any site where the patient is located, including urban areas and the patient’s home.</li><li>Permanently eliminating in-person visit requirements for tele-behavioral health, which would ensure patients do not need an in-person visit before initiating virtual treatment.</li><li>Permanently removing distant site restrictions on federally qualified health centers and rural health clinics, which would ensure that they can continue to provide telehealth services.</li><li>Permanently allowing payment and coverage for audio-only telehealth services.</li><li>Permanently expanding eligible telehealth provider types to include physical therapists, occupational therapists, speech-language pathologists and audiologists.</li></ul><h2>Conclusion</h2>We appreciate the committee’s attention to finding concrete pathways to update the Medicare physician payment system. We look forward to continuing working with you on this important initiative.Sincerely,/s/Lisa Kidder Hrobsky Senior Vice President Advocacy and Political Affairs Sun, 16 Jun 2024 23:20:10 -0500 Medicare Physician Payment CMS issues APM incentive payment advisory for clinicians /news/headline/2023-07-28-cms-issues-apm-incentive-payment-advisory-clinicians The Centers for Medicare &amp; Medicaid Services July 28 <a href="https://public-inspection.federalregister.gov/2023-16140.pdf">advised</a>&nbsp;clinicians in the Medicare Quality Payment Program who earned but did not receive an alternative payment model incentive payment in calendar year 2023 based on CY 2021 performance to update their billing information by Sept. 1 so it can disburse their payment. CMS was unable to verify current Medicare billing information for some qualifying APM participants when it disbursed the CY 2023 APM incentive payments. The advisory provides information on how these clinicians can update their billing information to receive their incentive payments.&nbsp; Fri, 28 Jul 2023 15:14:18 -0500 Medicare Physician Payment Medicaid Access and Payment Rules Webinar Your browser does not support the video tag. Thu, 08 Jun 2023 12:50:16 -0500 Medicare Physician Payment