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The Centers for Medicare & Medicaid Services (CMS) on August 3 issued a proposed rule that would update physician fee schedule (PFS) payments for calendar year (CY) 2021, and C-TAC submitted comments this week in response.

C-TAC was pleased that the agency included several proposals that would increase telehealth and scope of practice flexibilities. However, we were concerned about the redistributive effect of CMS’s budget-neutral proposed increases in the payment rates for office/outpatient evaluation and management (E/M) visits. More specific details below:

Telehealth

We are encouraging CMS to work with providers to ensure that telehealth is used when it is both clinically appropriate and in line with the patient’s wishes and needs. In line with our recent advocacy, C-TAC is asking CMS to make the allowance for audio-only delivery of Medicare advance care planning (ACP) permanent beyond the public health emergency. This change is especially important for those with serious illness from under-resourced and marginalized communities that may not have widespread access to broadband connectivity or smartphone technology. And while we support access to helpful telehealth services for those with advanced illness in most instances, for whom travel to clinic appointments can be burdensome to them or their loved ones, we also want to ensure that virtual encounters do not ultimately come to replace the many clinical interventions for those with serious illness that might be more appropriately delivered in-person.

Payment for Office/Outpatient Evaluation and Management (E/M) and Analogous Visits

We appreciate and support the rebalancing to increase the value of office-based E/M levels 4 and 5 codes, since these are often used when caring for patients with advanced illness due to their multiple issues and medical complexity. However, we have concerns that this payment increase is being balanced by a substantial decrease (roughly 8%-10%) in the rates for other PFS codes, including those for home and domiciliary E/M visits. We feel strongly that reducing payment rates for home-based care at a time when it has never been more important is problematic and has the potential to disincentivize care in the setting that most individuals with advanced illness prefer. We therefore suggested that CMS find other ways to balance the E/M increases.

Advance Care Planning and Clinical Social Workers

We applaud CMS’s recognition of the important role clinical social workers play in patient care and appreciated the addition of advance care planning to their specialty measure set under the Merit-Based Incentive Payment System (MIPS). Clinical social workers are trained to lead important conversations with patients and are often very effective at discussing advance care planning. We also recommended that, given the inclusion of advance care planning on this measure set, licensed clinical social workers be added to the list of those Medicare providers who can bill for advance care planning conversations under Medicare.

For more information about C-TAC’s regulatory and legislative work, please contact Policy & Advocacy Manager Davis Baird at dbaird@thectac.org.

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