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AAFP to CMS: 2012 Physician Fee Schedule Needs Work
By News Staff
Fairly Value Primary Care Services
"Effectively revaluing primary care and other cognitive codes will be essential to ensuring that there are a sufficient number of primary care physicians in the future," said Heim.
"The critical shortage of primary care physicians, who best manage the complexities of chronic care, results from the current flawed payment structure," said Heim. She urged CMS to improve the existing payment disparity by
- paying for services that currently are not covered, such as telephone calls and online medical evaluations;
- revisiting and adopting the median relative value units for outpatient evaluation and management codes that were originally submitted to the AMA/Specialty Society Relative Value Scale Update Committee, or the RUC, in 2007 (those values were substantially reduced by the RUC prior to adoption); and
- reimbursing certain "G" codes that relate to care provided in practices that offer patients a "certified" patient-centered medical home.
- In feedback on CMS' proposed 2012 Medicare physician fee schedule, AAFP Board Chair Lori Heim, M.D., focused attention on the need for CMS to more fairly appraise the value of the services primary care physicians provide to patients.
- Heim objected to CMS' proposal to require a health risk assessment as part of the annual wellness visit in 2012.
- The AAFP urged CMS to ensure proper metrics have been identified and vetted before launching the next phase of its physician performance reporting program.
Given the usual RUC process, potentially misvalued services remain that way for a full two years after they are identified, said Heim. "If CMS and the RUC are unable to develop a more timely process, then CMS should proceed to identify and adjust misvalued codes independently of the RUC."
Postpone Health Risk Assessment Requirement
Heim made it clear that although the AAFP supports the concept of the HRA as an evaluation tool that helps gather accurate information about a patient's health status, injury risks, modifiable risk factors and urgent health needs, CMS has yet to provide guidance to FPs on how to do this.
The HRA model, which was mandated by the Patient Protection and Affordable Care Act, has yet to be formulated. Development and availability to the public of an HRA model was supposed to be completed no later than 18 months after the Affordable Care Act was passed, but HHS Secretary Kathleen Sebelius has yet to meet this requirement.
Heim pushed the point: "While we understand CMS' desire to comply with the inclusion of the HRA into the AWV, it is unfair to hold physicians accountable for this portion of the Affordable Care Act when the Secretary has not yet fulfilled the crucial step of providing an HRA model.
"How can physicians successfully implement an HRA in January of 2012 when no model and no guidance are available?"
Furthermore, said Heim, the majority of HRAs in the current Medicare population will be handled by phone or during the patient's AWV and "will add a significant burden of time and expense for the practice."
CMS also underestimated the complexity of the documentation needed for each HRA completed, said Heim. The AAFP expanded the two-page form used to capture the elements of Medicare's initial preventive physical exam into a six-page form just to capture the additional elements of the AWV. The inclusion of an HRA "will reach another level of complexity," said Heim.
Improve Physician Quality Reporting System
Heim suggested that CMS
- continue to offer as many PQRS reporting options and timeframes as possible to facilitate successful participation by small to medium-sized groups,
- allow physicians to form "virtual" groups for PQRS reporting proposes,
- accelerate the requirement definition and the review process for qualifying PQRS registries,
- hold vendors accountable for successful data submission, and
- minimize administrative burdens if physicians are required to report on PQRS core measures that focus on cardiovascular conditions and only use measures endorsed by the National Quality Forum.
"The current 18-24 month lag time between the point of care and access to a feedback report is fundamentally not helpful from a quality improvement perspective," said Heim. "If the PQRS program is truly intended to improve the quality of physician services, the AAFP believes CMS must begin offering timelier (monthly or quarterly) interim feedback reports to PQRS participants."
Ensure Readiness Before Moving Ahead
"The AAFP reminds CMS that the Affordable Care Act stipulates that public reporting should only occur to the extent that scientifically sound measures are developed and available," said Heim. "The AAFP urges CMS to be aware of the possibility of penalizing physicians who see patients who are less willing or able to adhere to recommended care," she added.
Heim also advised CMS to avoid rushing the implementation of the next phase of improvements to the physician feedback program and the establishment of a new value-based payment modifier scheduled for implementation in 2015.
According to the law, CMS is to establish quality measures for the value-based modifier by 2012.
"CMS should not rush implementation of the value-based payment modifier and hastily adjust physicians' Medicare payments" before CMS' payment policies are clear, said Heim. "CMS must publicly develop further specifications surrounding this program while significantly improving the agency's capability of processing Medicare claims and performance data in a more meaningful and real-time manner," she added.
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2012 Physician Fee Schedule Needs Work, Says AAFP