The Academy reacted promptly when CMS apparently disregarded comments from the AAFP and other organizations on proposed payment for self-contained hemoglobin A1c testing systems for physician office use. A follow-up letter fired off to CMS in late September noted the Academy's objections to CMS' proposed payment.
"There is no reference to the AAFP's recommendation in the spreadsheet of payment recommendations online," wrote (then) Board Chair Michael Fleming, M.D., of Shreveport, La., adding that other medical specialty societies also submitted recommendations that were not referenced in the spreadsheet.
AAFP submitted comments in July, well within CMS' allotted time frame for commenting on the proposed payment. Comments were to be accepted until Sept. 23.
"We believe that our comments and the comments of all groups that submitted a recommendation for the public meeting should be registered on the summary on the CMS Web site, and we do not believe it is appropriate to make a payment determination without considering all of the relevant comments and recommendations," said Fleming.
Fleming noted in the letter that CMS gave no clear rationale for its proposed payment level. "We believe CMS owes everyone involved a clear explanation for why it chose the alterative it did. In the absence of such a rationale, CMS' proposal seems arbitrary and unjustified," he said.
Fleming urged CMS to reconsider its proposal, pointing out that diabetes management in the United States is inadequate, demonstrating an overall downward trend in outcomes for patients treated in a primary care setting.
"There is an urgent need to improve access to A1c testing in the primary care setting to help improve this unnecessary situation. Real-time A1c, at the time of the patient visit, is required for effective and intensive management that is proven to improve the health status for patients with diabetes," said Fleming.
In the letter, the Academy again proposed payment of $21.06 for the testing. "We believe this is a small price to pay to provide universal access to the basic indicator required for effective and cost-efficient diabetes management at the point of care," said Fleming.
