In response to the Centers for Medicare & Medicaid Services’ proposed 2017 physician fee schedule, advocacy groups are offering generally supportive comments, though concerns linger, particularly around physician reporting burdens.
The CMS proposal includes proposed changes expected to yield approximately $900 million in additional funds for primary care physicians, which is welcome news to the American Academy of Family Physicians.
“By better valuing primary care and care coordination, CMS is helping improve Medicare beneficiaries’ access to services they need to stay well,” said AAFP Board Chair Robert Wergin, M.D.
The organization was less bullish on the rule’s omission of a plan for improving Medicare’s annual wellness visit, which Wergin says is prone to “potential misuse” by commercial nonphysician entities. The AAFP also notes continuing concerns about the compliance burden physicians face dealing with appropriate use criteria (AUC).
The American Hospital Association praised the rule’s addition of new telehealth services for rural areas, the integration of behavioral health services into primary care, and expansion of the Diabetes Prevention Program model in its statement. In its detailed comments (.pdf), however, the group also expressed concern about the time line for compliance with the AUC, particularly given the relatively short time between designation of qualified clinical decision support mechanisms and the proposed compliance date.
In its comments on the rule, the American Medical Group Association recommended further refinements around CMS’ definition of an “initiating visit” for visits covered by behavioral health codes, and suggested CMS incorporate AUC for advanced diagnostic imaging into reporting for the Merit-Based Incentive Payment System as a means of reducing its burden on physicians’ resources.
“Ultimately, appropriate use is about measuring and influencing resource use,” said Donald W. Fisher, Ph.D., the organization’s president and CEO. “Rather than create a separate reporting and measurement structure, CMS should align the appropriate use program with the MIPS resource use component score.” The group also suggested CMS make its proposed beneficiary consent requirements for chronic care management available for all three Medicare Shared Savings Program tracks.