American College of Physicians (ACP) Provides Insight in a Letter to CMS on the Proposed Rule for the 2016 Medicare Physician Fee Schedule
September 9, 2015
In a 47-page letter to the Centers for Medicare and Medicaid Services (CMS), ACP provides its comments on the proposed rule for the Calendar Year (CY) 2016 Medicare Physician Fee Schedule (PFS). CMS will review comments from ACP and all other stakeholders and then issue a final PFS rule in late October/early November-this final rule will lay out the 2016 payment policies for all physicians and other eligible professionals that participate in Medicare Part B.
Among its many comments, ACP's letter made the following high priority recommendations:
- Called on CMS to expand the Comprehensive Primary Care (CPC) Initiative both to additional geographic regions, as well as in existing CPC initiative areas. The CPC initiative, a Medicare-funded pilot test of the impact of advanced Patient-Centered Medical Homes on quality and cost of care, is currently limited to approximately 500 practices in 7 market areas. The College believes that there is sufficient evidence on its effectiveness in improving quality and/or achieving savings to support making it widely available to beneficiaries and practices across the country. ACP recommended that CMS seek out agreements with other payers in additional regions of the country to join with Medicare to support practices that wish to participate in the CPC initiative, and to open up participation to more practices in the current CPC initiative regions.
- Supported CMS's proposal to allow Medicare reimbursement for advance care planning services. While this proposal is an important step to improve care for Medicare patients with serious illness, ACP urged that reimbursement for advance care planning be made uniformly available to all physicians and their Medicare patients through a national coverage determination, rather than leaving it to each regional Medicare carrier to decide whether to cover the service.
- Urged CMS to reduce barriers to physicians getting reimbursed for the Chronic Care Management (CCM) Code and allow reimbursement for CCM services that require additional time. ACP recommended that CMS develop add-on codes for time increments greater than 20 minutes such as 21-40 min; 41-60 min; and greater than 1 hour. ACP also recommends that the electronic care plan sharing requirement for providing the CCM service be suspended until such time that EHRs have the ability to support such capabilities.
- Encouraged CMS to use payment approaches that are aligned with the goal of moving payments away from volume to value-based care such as by exploring bundling of codes for certain chronic diseases. More specifically, ACP recommended that a code bundle for Diabetic Care Management (DCM) be developed to emphasize better care coordination, communication, and integration of the care team aimed at a better overall outcome cost of care for the Medicare beneficiary.
- Supported CMS' recognition of the need to value the delivery of behavioral health services within the Physician Fee Schedule. ACP recommended that the "collaborative care" model described in the proposed rule be implemented through a Center for Medicare and Medicaid Innovation (CMMI) demonstration and be rapidly expanded within Medicare through the Secretary's authority based upon the results and learnings of this demonstration.
- Recommended that CMS review its approach and identify better ways to reach the relative value unit (RVU) reduction target established by the Protecting Access to Medicare Act of 2014 (PAMA) law and as accelerated by the Achieving a Better Life Experience (ABLE) Act. Therefore, ACP recommended that codes with large volume changes, due to a new structure of the codes, be included in the target for reductions.
- Recommended that CMS investigate the adequacy of payment for physician services that typically take place outside of a face-to-face patient encounter. The College urged CMS to recognize non-face-to-face services-- such as telephone and email consultations-- that facilitate care coordination by internists and other primary care physicians.
ACP's letter also offered comments on:
- Additional specific coding issues, such as Practice Expense (PE) determination, moderate sedation valuation, and surgical global periods.
- Physician Quality Reporting System (PQRS)
- The Value-Based Payment Modifier and Physician Feedback Program
- Physician Compare
- The Medicare Shared Savings Program (MSSP)
- Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging Services
- CMS's request for comments on issues relating to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) implementation
The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 143,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter and Facebook.
Contact: David Kinsman, (202) 261-4554