The AAFP has asked CMS to adopt a series of short-term strategies for improving primary care payment that are based on recommendations developed by the AAFP's Primary Care Valuation Task Force.
In a March 12 letter(10 page PDF) to CMS Acting Administrator Marilyn Tavenner, M.A., AAFP Board Chair Roland Goertz, M.D., M.B.A., of Waco, Texas, said the recommended strategies would not save primary care in the short-term, but they would "provide some desperately needed short-term help that family medicine and primary care needs until payment reform efforts are complete and long-term strategies can be identified and implemented."
The AAFP created the Task Force on Primary Care Valuation last June, pulling in representatives from medical specialty societies and health care experts from academic institutions and the private sector to identify solutions to a system that has contributed to inequitable and devalued payment for primary care medical services.
The task force was in part a response to a perception that the AMA/Specialty Society Relative Value Scale Update Committee (RUC), which provides guidance on payment rates for CPT codes to CMS, was not properly valuing evaluation and management (E/M) services. The task force focused on finding ways to more appropriately appraise the worth of E/M services, which most often are provided by primary care physicians, especially family physicians.
- The AAFP has asked CMS to adopt strategies for improving primary care payment that are based on recommendations issued by the Academy's Task Force on Primary Care Valuation.
- The recommendations call for new codes for E/M services, payment for telephone and online E/M services and enhanced payment options for primary care physicians based on certain fundamental precepts.
- If adopted by CMS, the recommendations would improve payment for primary care services by primary care physicians in the near term and support principles for longer term payment reform.
During the past seven months, the task force developed a series of recommendations on various payment issues, including
- new codes for E/M services,
- enhanced payment options for primary care physicians that are based on three definitional functions of primary care,
- enhanced payment options for primary care physicians based on certain fundamental precepts, and
- payment for telephone and online E/M services.
The AAFP Board approved the recommendations during a meeting last week in Washington.
If adopted by CMS, in the near term, the recommendations would lead to improved payment for primary care services that are provided by primary care physicians. In addition, the recommendations support principles for long-term primary care payment reform that were developed by the Patient-Centered Primary Care Collaborative, said Goertz.
The first of the task force's recommendations calls on CMS to create new codes for E/M services provided by primary care physicians with relative values that would, at the very least, equal or exceed the median survey values from a 2005 survey of E/M codes. The survey was conducted by primary care and other cognitive specialties.
"Given that the bulk of primary care payment is derived from a fee-for-service payment model based on current E/M codes, the AAFP believes that it is important to ensure that the E/M codes used by primary care physicians accurately reflect the work required and (are) appropriately valued," said Goertz.
A second recommendation from the task force urges CMS to recognize that eligibility for enhanced payment options for primary care physicians should be based on fundamental precepts of primary care, including care that initiates first contact and that demonstrates continuity and comprehensiveness.
"The definition of primary care in this country varies in different contexts, but it consistently encompasses certain core values, including first contact of care, continuity of care, comprehensiveness, and coordination of care," Goertz said. "The AAFP believes that to appropriately identify primary care physicians, CMS must use a working definition that reflects the core definitional elements."
The AAFP also is urging CMS to pay for certain services as part of the Medicare physician fee schedule by using established relative value units (RVUs) when these services are provided by primary care physicians. The services are
- telephone evaluation and management services (CPT codes 99441-99443);
- collection and interpretation of physiologic data (CPT code 99091);
- domiciliary, rest home or home care plan oversight services (CPT codes 99339-99340);
- anticoagulant management (CPT codes 99363-99364);
- medical team conferences (CPT codes 99366-99367); and
- care plan oversight services (CPT codes 99374-99380).
"All of the services covered by this recommendation have established RVUs," said Goertz. "However, CMS does not pay for them separately under the Medicare physician fee schedule. CMS considers most of them 'bundled' with other services paid under the fee schedule."
Some of these services and their corresponding codes likely would be part of a care management fee, said Goertz. But, "The AAFP believes that paying for them now on a fee-for-service basis is a sound and interim short-term strategy."
The final recommendation from the AAFP calls on CMS to value and pay for online E/M services (CPT code 99444) provided by primary care physicians.
The AAFP believes that online E/M services are as integral to primary care as other nonface-to-face services, said Goertz. "Since CMS has the ability to value services independent of the RUC, the AAFP recommends that CMS proceed to work directly with AAFP and other organizations that represent primary care physicians to establish a value for this service and implement payment for it under the Medicare physician fee schedule in 2013."
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