AAFP calls on CMS to act to stabilize primary care practices



Repeating the recommendations it made last year, the Academy again urged CMS to “recognize the additional costs physicians’ practices incur to protect their staff and patients from COVID-19” – an appeal rendered more urgent by the surge of the delta variant. Offsetting primary care practices for the ever-increasing costs associated with personal protective equipment, social distancing and proper cleaning of equipment and patient rooms “is critical to ensuring they can stay open. and caring for patients during this national emergency, especially as the practices face reductions in Medicare payment rates in 2022, ”wrote the AAFP. To achieve this, the agency should make code 99072 an active code (status A), “paying for it appropriately, based on the recommendations of the (Relative Value Scale Update Committee) and ‘others”.

Assessment and management

In a year when primary care practices were expected to reap the benefits of a long overdue increase in payments, many primary care physicians are still waiting.

“Most family physicians are salaried physicians, and many of their employers do not reflect increases in relative value units or Medicare allowances in their employment contracts,” the Academy wrote. “Instead, employers are keeping their employed physicians’ contracts at 2020 levels and pocketing increased Medicare payments for codes 99202-99215 or using those payment increases to offset decreases elsewhere in the fee schedule.”

“AAFP urges CMS to use the tools at its disposal, including rule development and sub-regulatory guidance, to help ensure that the assessment and management of UVR increases in 2021 are passed on. to primary care physicians, ”the letter reads. “We understand that physician contracts with private payers and organizations that employ physicians are outside the purview of CMS. However, we think it is important for CMS to know what is going on in this regard, as it is considering further efforts to support primary care.

Relative value units of practice expenses

CMS assigns relative value units to all services paid for under the Medicare Physician Fee Schedule based on three factors: physician work, practice fees, and malpractice fees. A service’s RVUs are then multiplied by a conversion factor (the dollar amount CMS pays per RVU) and adjusted geographically to determine the amount allowed by Medicare.

The Relative Value Scale Update Committee, the Expert Panel whose members include the AAFP, and a number of other national specialty societies influence the determination of VUR. CMS takes the RUC’s recommendations into account when deciding which SVRs to assign to each service covered by Medicare.

In 2022, after almost two decades of no change, CMS is proposing to update the Clinical Labor Pricing Factor – a factor in calculating SVRs of practice spending – using the most recent data from the Bureau of Labor Statistics as a source. main.

“We support this update and believe, after nearly 20 years, that it is long overdue,” the Academy said, noting that the delay in adaptation has likely put family medicine at a disadvantage for years. “This update will help ensure that the SVR methodology of CMS practice expenses more closely approximates the most recent practice expenses incurred by family physicians.

“We encourage CMS to fully implement the clinical work pricing update in 2022 and not phase in the changes over four years,” the letter added. “Further extending the needed improvement in the RVU methodology of CMS practice spending will cause unnecessary additional delays for an already overdue price update. “

Administration of vaccines

CMS used the Schedule of Fees to solicit feedback on how best to update the payment methodology for administering vaccines, recognizing – as the Academy has long pointed out – that Medicare’s payment for the insufficient service.

“The AAFP strongly recommends that CMS implement the RUC Spring 2021 recommendations for vaccine delivery services,” the letter reads. Highlighting the importance of such an update, the Academy cited results from the 2020 survey indicating that 80% of responding physicians said increasing vaccine administration payment rates would help overcome the barriers and vaccine costs associated with the pandemic. “Coupled with low immunization rates among beneficiaries, these results suggest that updated Medicare payment rates for routine and seasonal immunizations are urgently needed,” the letter said.

The Academy also suggested that CMS develop “a payment methodology for vaccine administration that considers the value of preventive vaccinations rather than just looking at the cost of providing those services.”

The proposed rule would continue to provide additional payment to doctors to provide COVID-19 vaccines to patients at home, the Academy’s policy has praised.


The proposed rule would keep certain services added to Medicare’s list of telehealth services on a Category 3, or temporary basis, until the end of 2023, a move the Academy has supported while urging CMS to add the codes. E / M phone calls to Medicare telehealth services. on a Category 3 basis, as well as to implement a more permanent solution for audio-only services. “Audio-only telehealth services have been crucial in improving equitable access to care during PHE,” wrote the AAFP.

The letter expressed strong support for the rule’s proposal to change the definition of “interactive telecommunications system” and permanently allow audio technology only for tele-mental health services, but opposed the requirement according to the letter. which in-person service must be provided within six months of receiving a telehealth mental health service. “The evidence does not support the need for such a continued demand for mental health services,” the Academy said. “We oppose arbitrary in-person service requirements for mental health services. “

The Academy also supported proposals to implement the removal of geographic restrictions and add the home as the home site for tele-mental health services after the public health emergency ends. This final step “would improve access to mental and behavioral health care for beneficiaries, many of whom may find it difficult to easily access these services in their communities,” AAFP said.

Administrative simplification

Following constant advocacy from the AAFP, CMS proposes as a rule to delay the full implementation of the Appropriate Use Criteria program for advanced diagnostic imaging until January 1, 2023 or January 1 of the following year. the end of the COVID-19 public health emergency, according to the later. The delay could give Congress a chance to repeal the program, a result the Academy has also been pushing for.

Expressing its strong support for this change, the Academy reiterated its position that the AUC program “is too cumbersome, complex and… does not take into account quality, patient outcomes or other important factors, which are better taken into account in alternative payment models ”.

Quality payment program: merit-based incentive payment system

The changes proposed in the fee schedule to the traditional MIPS component of the QPP consist in particular of ensuring that the performance threshold is 75 points in 2022 and the exceptional performance threshold at 89 points. The cost category would be weighted at 30% of the MIPS score, and the rule would add five new episode-based cost metrics, including two for chronic disease. The categories of quality, interoperability promotion and improvement activities would be weighted at 30%, 25% and 15% respectively.

The AAFP has expressed concern about the progress of the MIPS program despite the latest increase in COVID-19 cases. “Setting the performance threshold at 75 for the 2022 performance period will represent a 30 point increase from the 2020 performance period,” the Academy said – a sharp increase that the ongoing pandemic will make untenable for many practices. “The AAFP encourages CMS to explore ways to use its authority, including emergency authorities under the PHE, to adjust the performance threshold from the 2022 performance period.”

The AAFP also called on CMS to apply the extreme and uncontrollable circumstance exception for the 2021 performance period. “It is essential that family medicine and other medical practices focus on providing patient care during this period and are not required to go through a cumbersome MIPS reporting process, ”the letter said.

MIPS Value Path

The Academy objected to elements of the rule’s transition schedule proposed to replace traditional MIPS reporting with the MIPS Value Pathways program, which is expected to begin in 2023. The agency’s goal is a more reporting option. targeted, and plans to phase out traditional MIPS in 2027.

“We hope that MVPs can serve as a pathway to prepare practices for the transition from fee-for-service,” the Academy said, preferring a number of suggestions on how CMS could “significantly reduce the fee for service. burden of reporting to MIPS. ”For example, the Academy pointed out that CMS’s prioritization of an MVP focused on chronic care management, a core tenet of primary care, includes several cross-category credit opportunities, allowing family physicians “a more significant and less burdensome reporting experience”.

“However, we remain concerned that the transition away from FFS will be hampered by the dearth of APM available for practices – especially small practices and independent practices,” the letter added. “We strongly urge CMS to work with the Center for Medicare & Medicaid Innovation to develop a clearer path outside the FFS for all practices, including the development of options that span the spectrum of risk.”



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