On September 11, AHCA/NCAL
submitted public comments on the Centers for Medicare and Medicaid Services (CMS)
Proposed Rule containing multiple proposed policy changes impacting Medicare Part B payment policy, Medicare alternative payment quality models, Medicare advantage, and Medicare and Medicaid provider enrollment policies that impact AHCA/NCAL member communities and the residents they serve.
Key AHCA/NCAL comments with broad implications include:
- Strongly opposing the proposed Conversion Factor reduction of 3.36 percent and asking CMS to consider deferring the implementation of the Evaluation and Management (E/M) complexity code that is the primary driver of the reduction and permit a comprehensive reassessment of the policy as intended by Congress when the implementation was previously delayed.
- The sunset of the Geographic Practice Cost Indices (GPCIs) would eliminate the 1.0 multiplier floor unless Congress intervenes. This could result in significant additional payment reductions for providers, particularly those in rural and underserved areas. Absent of Congressional relief, the Association recommending that CMS consider mitigation strategies, such as a phase-in approach.
- Strongly recommending that CMS suspend the application of the multiple procedure payment reduction (MPPR) policy for 19 therapy codes that CMS identified in the proposed rule as being underpaid since 2018, until CMS can implement the recommended revaluation of these codes from the AMA RUC HCPAC (American Medical Association’s Relative Value Scale Update Committee and Healthcare Professional Advisory Committee Review Board) – which to our understanding, could be delayed.
- Strongly supporting several proposed telehealth policies including those related to geographic restrictions, physical and occupational therapy and speech language pathology services, and the removal of certain physician telehealth services limits for follow-up care.
- Offering caution to specific proposed changes to provider enrollment policies to expand criminal background checks for persons reported on the CMS-855 provider enrollment documentation to include misdemeanors during the prior 10-years as potentially burdensome, overreaching, and discriminatory.
- Requesting that CMS establish clear guardrails to address concerns raised to prevent unintended consequences before considering finalizing the proposal.
Below is a list of 12 subject areas discussed in the 22-page
comment letter:
- Changes in Relative Value Units (RVUs)
- Geographic Practice Cost Indices (GPCI)
- Potentially Misvalued Services Under the PFS
- Payment for Caregiver Training Services (CTS)
- Payment for Medicare Telehealth Services Under Section 1834(m) of the Social Security Act
- Other Non-Face-to-Face Services Involving Communications Technology Under the PFS
- Extend Billing Flexibilities for Certain Remotely Furnished Services Through CY 2024
- Advancing Access to Behavioral Health
- Medicare Shared Savings Program
- Payment for Dental Services Inextricably Linked to Specific Covered Services
- Medicare and Medicaid Provider and Supplier Enrollment
- Updates to the Definitions of Certified Electronic Health Record Technology