In public comment letters on physician payment rules for next year, healthcare providers offer conditional praise for plans to reform reimbursement for primary care, preventive services, and care coordination.
Key elements of proposed changes to Medicare's Physician Fee Schedule (PFS)—improved payments for primary care, preventive services and care coordination—have drawn scrutiny in public comment letters to federal officials.
The Centers for Medicare & Medicaid Services (CMS) released the 2017 PFS proposed rule in July, and CMS Acting Administrator Andy Slavitt heralded the payment changes as a significant boost to providers of primary care services. "We conservatively estimate that these changes would result in approximately $900 million in additional funding in 2017 to physicians and practitioners providing these services," Slavitt wrote in the CMS Blog on July 7.
Examples of the payment improvements for primary care, preventive services and care coordination include:
- Increasing payments for routine office visits for patients with mobility-related disabilities from $73 to $119.
- Removing barriers to payment for Diabetes Self-Management Training (DSMT) services.
- Payment for behavioral health services through Medicare's Collaborative Care Model, a team-based approach to treatment with psychiatric consultants, behavioral healthcare managers and primary care physicians.
In the American Medical Association's public comment letter on the PFS proposed rule, Executive Vice President and CEO James Madara, MD, strikes a generally positive tone:
"The AMA supports CMS' proposals to improve payment accuracy for primary care, care management, and patient-centered services. Specifically, we support a separate payment for non-face-to-face prolonged Evaluation and Management (E/M) services, separate payments for services furnished using the Psychiatric Collaborative Care Model (CoCM), the implementation of other codes in the Current Procedural Terminology (CPT) family of Chronic Care Management (CCM) services, and a separate payment to recognize the work of a physician in assessing and creating a care plan for beneficiaries with cognitive impairment."
Madara's letter does mention several suggested changes to the PFS proposed rule, including the contention that CMS' plan to boost payments for patients with mobility-related disabilities is at odds with provisions of the Medicare Access & CHIP Reauthorization Act (MACRA).
"The AMA opposes CMS' plan to eliminate the 2017 physician payment increase Congress provided in MACRA in order to fund an add-on payment for services provided to patients with mobility-related disabilities. While the AMA supports payment policies that improve access to care for patients with these and other impairments, there is no justification for funding these services with an overall cut in physician payment rates. Following years of threats of significant payment reductions under the SGR formula, physicians had expected to receive a 0.5 percent update in 2017, as provided in MACRA."
In its comment letter, the American Medical Group Association praised CMS for boosting payments for CCM services, but also criticized plans to increase patient co-payments.
"By proposing to recognize and pay for other codes in the Current Procedural Terminology (CPT) family of CCM services, CMS has acknowledged AMGA's concern that the 20 minutes per month, per patient may not sufficiently recognize and reimburse all CCM services delivered," President and CEO Donald Fisher, PhD, wrote.
"We do remain concerned that use of the CCM codes requires beneficiaries pay a 20% copayment for the service. AMGA medical groups have repeatedly stated that they have found it difficult to make known or enforce the copay requirement because these services had been previously provided for free. AMGA members feel that the chronic care management code should be considered a preventive service."
The 2017 PFS final rule is expected to be released by Nov. 1.