(Washington, July 8, 2016) A new proposed rule by the Centers for Medicare and Medicaid Services (CMS) will greatly strengthen the ability of primary care physicians to provide high value, coordinated and patient-centered care to their patients enrolled in Medicare, said the American College of Physicians (ACP) today. While the College plans to comment later in detail on the proposed rule, ACP's initial review suggests that the proposal rule, combined with other recent policies proposed by CMS, will effectively help break down long-standing barriers to effective treatment of patients enrolled in Medicare who have chronic and/or behavioral health conditions.
ACP is the largest medical specialty organization and the second-largest physician group in the U.S. ACP members include 148,000 internal medicine physicians (internists), related subspecialists, and medical students.
The proposal, published yesterday in the Federal Register, includes a number of ACP-supported changes in Medicare payment policies to increase payments to internal medicine specialists and other primary care physicians for coordinating care of patients with complex chronic illnesses, for integrating treatment of behavioral health conditions into primary care, and for improving care of patients with diabetes. It also proposes increases in the relative value units that determine payments for office visits and other evaluation and management services. Specifically, the College noted that the proposed rule includes the following improvements:
Payment for Care Coordination by Primary Care Physicians: The proposed rule includes revisions to the billing requirements for the existing chronic care management (CCM) codes to address the administrative burdens of electronic access, use of certified EHRs, and documentation. CMS is also proposing payment for two additional codes to address the amount of time patients with complex needs require for extra care management. ACP has long-urged CMS to make payment for more time-intensive care coordination services to patients with multiple chronic conditions and to make it administratively easier for physicians to bill for such codes.
The Agency also proposes to recognize payment for codes related to non-face-to-face prolonged evaluation and management (E/M) services and increase payment rates for face-to-face prolonged E/M services. These codes provide a means to recognize the additional resource costs incurred by physicians when they spend significant time outside of the in-person office visit.
Integrating Mental and Behavioral Health into Team-based Primary Care: CMS is proposing to pay for specific behavioral health services furnished using the Collaborative Care Model; in this model, patients are cared for through a team approach, involving a primary care practitioner, behavioral health care manager, and psychiatric consultant. CMS is also proposing to pay more broadly for other approaches to behavioral health integration services. Last year, ACP published a position paper on the integration of behavioral health into primary care calling on Medicare and other payers to authorize payment for such services.
Cognitive Impairment Care Assessment and Planning: CMS is proposing a new code 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.
Care for Patients with Mobility-Related Impairments: CMS is proposing to pay physicians more accurately for furnishing services to beneficiaries with mobility-related impairments. This increase in payment will improve quality and access for this vulnerable population.
Expansion of Diabetes Prevention Program (DPP) Model: The proposed rule would expand to eligible patients and physician practices in all states this CMMI model, now available in only eight states, which provides counseling and other support services to help prevent diabetes in patients that have been found to be at a greater risk of becoming diabetic. Physicians and other clinicians who participate in the program would receive additional payments for providing such support services to their eligible patients. ACP strongly supports CMS's expansion of this prevention model and is pleased that it met the legal Actuarial requirements required for CMMI to expand it nationwide, and will be providing comments on the basic framework outlined in the proposed rule.
Addressing Undervaluation of Primary Care Services: CMS notes in the proposed rule that the current set of codes for primary care evaluation and management services, like office visits, do not adequately reflect the resources involved in providing such services, and seeks comments on improving the relative value units assigned to such codes to more accurately reflect their resource costs.
Valuation of Global Services: The Agency proposes a strategy to begin data collection on the activities and resources involved in furnishing global services, which can then be used to revalue these services.
Medicare Shared Savings Program (MSSP): CMS proposes to make modifications to policies related to MSSP Accountable Care Organizations (ACO) to better align quality reporting with proposals for the Quality Payment Program (QPP). The rule also includes a proposal to allow beneficiaries to voluntarily attest to the primary care clinician of their choice through an automated process in all three MSSP ACO tracks. ACP supports policies to better align the MSSP program with the QPP and allow beneficiary attestation in MSSP ACOs.
These and other improvements proposed by CMS would increase aggregate payments to physicians, especially those who practice in primary care specialties including internal medicine, by approximately $900 million said CMS in an accompanying blog post.
ACP noted that the proposed rule is just the latest example of positive steps CMS is taking to strengthen primary care, including the announcement earlier this year of the Comprehensive Primary Care Plus program, which will provide risk-adjusted monthly per patient care coordination payments to primary care physicians in approximately 5000 Patient-Centered Medical Home practices in 20 regions.
In addition, in the recent Hospital Outpatient Prospective Payment System proposed rule for 2017, CMS proposed other payment and regulatory changes supported by ACP, including:
- Allowing physicians to satisfy current 2016 Meaningful Use requirements by reporting on only 90 days of activities rather than a full year.
- Strengthening a "site-neutral" payment policy that eliminates excess facility payments for hospital-owned physician practices.
"As a practicing primary care internist myself, I am greatly encouraged that CMS is proposing substantial improvements to help me and my colleagues provide coordinated, patient-centered, high value and team-based care to our patients" said Nitin S. Damle, MD, MS, FACP, ACP president. "We look forward to providing CMS with detailed comments to support these improvements while recommending other changes to strengthen primary care."
The American College of Physicians is the largest medical specialty organization and the second-largest physician group 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. Follow ACP on Twitter and Facebook.