AAFP to CMS: Decrease Financial, Administrative Burdens on FPs

AAFP challenged CMS recently on the federal agency's estimation of the financial burdens placed on family physicians who supply Medicare patients with the required Advance Beneficiary Notice of Noncoverage, or ABN, form.

By Academy calculations, CMS' current estimate of about $69 per notifier per year to provide and complete ABN forms actually should be increased to closer to $275 to take staff time and other resources into account, said AAFP Board Chair Larry Fields, M.D., of Flatwoods, Ky., in an April letter to CMS about proposed revisions to the ABN.

Fields also suggested that CMS increase -- by 50 to 100 times -- the number of ABNs it estimates individual family physicians generate each year.

"The estimated 31.7 ABNs per notifier is seriously underestimated for most family physicians," said Fields. "To aid physicians who continue to provide care to the growing number of Medicare beneficiaries, we urge CMS to seek ways to lessen the administrative burdens associated with Medicare whenever possible," he added.

Fields also suggested CMS consider physician-friendly changes to the ABN form itself, such as avoiding overuse of regional policies developed by local Medicare carriers and policies developed at the national level by CMS. "Each local and national coverage decision requires substantial administrative work to review, track and integrate into practice workflow," said Fields.

Fields agreed with CMS' proposal to use one form for both general and laboratory noncoverage notifications. However, he suggested that the proposed single form include language already used in the current laboratory ABN -- namely, a sentence that would instruct the patient to inform his or her primary care physician when the patient refused testing that would not be covered.

"This instruction is pertinent to maintaining the physician-patient relationship and continuity of care," said Fields. "With Medicare patients often seeing multiple physicians in different practices, it is especially important that the patient contact their primary care physician when faced with a decision to forgo recommended testing or pay for it out-of pocket.

"This may become even more critical as Medicare moves toward value-based purchasing of physician services (also known as pay-for-performance)," added Fields.