The American College of Physicians (ACP) is pleased that the 2017 Medicare Physician Fee Schedule final rule by the Centers for Medicare and Medicaid Services (CMS) includes several important initiatives to support high-value primary care. The policies in the rule more accurately recognize the work of primary care physicians and other cognitive specialties to accommodate the changing needs of Medicare beneficiaries. ACP applauds CMS for being responsive to the numerous policy recommendations from ACP that we submitted on the initial proposed rule.
The steps taken by CMS to support primary care, reduce barriers to chronic care management, improve access to behavioral health services, and prevention included the following:
- Payment for Care Coordination by Primary Care Physicians: The final rule will help reduce barriers to effective care of patients with chronic illnesses by allowing payment for more complex, time-intensive chronic care management (CCM) services. ACP supports CMS' removal of the health information technology (HIT) requirements necessary to bill CCM codes
- Addressing Undervaluation of Primary Care Services: The new rule adopts current procedural terminology (CPT) guidelines for separate payments for non-face-to-face prolonged services. ACP also appreciates CMS' review of alternative code proposals containing varying levels of intensity and time increments for prolonged services and their willingness to keep these proposals open for future consideration and rulemaking.
- Cognitive Impairment Care Assessment and Planning: The final rule finalizes a new code and policies to pay for cognitive and functional assessment and care planning for patients with cognitive impairment (e.g., for patients with Alzheimer's). This is a major step forward in care planning for these populations.
- Integrating Mental and Behavioral Health into Team-based Primary Care: CMS is implementing a new evidence-based approach to caring for patients with behavioral health conditions through the Psychiatric Collaborative Care Model (CoCM) as well as the expansion of the Medicare Diabetes Prevention Program - allowing Medicare beneficiaries to access preventive diabetes services without being subject to co-payments while providing participating physicians and other clinicians additional payments for furnishing preventive services to eligible beneficiaries.
- Medicare Shared Savings Program (MSSP): CMS finalized modifications to policies related to MSSP Accountable Care Organizations (ACO) to better align quality reporting with proposals for the Quality Payment Program (QPP). We are pleased that the final rule also includes an allowance for beneficiaries to voluntarily attest to the primary care clinician of their choice through an automated process in all three MSSP ACO tracks.
In other rulemaking, CMS finalized other payment and regulatory changes supported by ACP. The recently released Hospital Outpatient Prospective Payment System Final Rule for 2017 includes several policies strongly supported by ACP:
- Site-Neutral Payments: ACP supports CMS finalizing their policy on relocation of excepted Off-Campus provider-based departments (PBDs) and appreciates CMS adding a modification to the final policy to allow for "hardship" exceptions for extraordinary circumstances (i.e., natural disaster) - which will be reviewed by CMS on a case-by-case basis. ACP will continue to work with the Agency to advocate for restrictions on the scope of services "excepted" off-campus PBDs are able to furnish and bill at the higher OPPS rate - but is appreciative that CMS will monitor the expansion of these services and continue to consider whether a restriction on service line expansion should be adopted in the future.
- EHR Incentive Program: ACP supports CMS finalizing a 90-day reporting period for the EHR Incentive Program in 2016 and 2017.
- Proposed Hospital Value-Based Purchasing (VBP) Policies: ACP is very supportive of CMS removing the Pain Management Dimension of the Hospital Consumer Assessment of Healthcare Providers and Systems (HCAHPS) survey. Many stakeholders, including ACP, have suggested that maintaining this survey could put pressure on hospital staff to prescribe more pain medications such as opioids to achieve a higher HCAHPS score, which may further contribute to the opioid overdose epidemic.
The American College of Physicians is the largest medical specialty organization in the United States. ACP members include 148,000 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.