AAFP to CMS: Don't Add to Physicians' Administrative Burden

Changing Exchange Reenrollment Process Would Disrupt Patient Care

March 04, 2020 01:43 pm News Staff

The AAFP recently warned CMS that altering the Patient Protection and Affordable Care Act's automatic reenrollment policies for federal and state exchange plans would harm patients, destabilize the market and increase administrative burden for physician practices.

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"To meaningfully provide stakeholders with a stable regulatory environment while also empowering consumers and ensuring program integrity and affordability, the AAFP implores CMS to continue automatic reenrollment policies," the Academy said in a March 2 letter(2 page PDF) to CMS Administrator Seema Verma, M.P.H., signed by Board Chair John Cullen, M.D., of Valdez, Alaska.

The AAFP was responding to a proposed rule from CMS that was published in the Feb. 6 Federal Register.(www.govinfo.gov) The rule establishes payment parameters and risk adjustment policies, as well as other policy updates for federal and state-based health care exchanges. CMS asked for comments regarding possible modification to the automatic reenrollment process for certain enrollees, but the agency did not propose specific changes.

"CMS should continue automatic reenrollment into the same or similar health plans during the open enrollment period, regardless of a consumer's required premium contribution," the Academy wrote. "HHS should avoid policies that lead to disruptions in coverage and lapses in care, both of which ultimately lead to worse outcomes and more costly care."

The letter added that modifying automatic reenrollment policies would destabilize the market, noting that the agency "preemptively acknowledged that stakeholders are uniformly against the idea of discontinuing auto-reenrollment."

"Besides destabilizing the market, discontinuing automatic reenrollment could negatively impact patient care, since plan changes disrupt the patient-physician relationship and threaten longitudinal care," the Academy said.

Among the possible disruptions: Patients forced to enroll in a new plan could have to repeat prior authorization or step-therapy hurdles, threatening the stability of their medication or treatment plans.

These patients, the Academy said, should not face mandatory step therapy if they're already on a treatment course.

Step therapy increases administrative burden for physicians, the letter added. The Academy cited a 2016 study(annals.org) published in Annals of Internal Medicine that showed primary care physicians spend nearly half their time on "cumbersome administrative tasks" that take time away from direct patient care, including prior authorization, performance measurement, EHR documentation and care management documentation.

"This inefficiency and time diverted from patient care is clearly not acceptable, and patients should not be required to repeat or retry step therapy protocols failed under previous benefit plans," the Academy said.

The AAFP's recommendations on prior authorization and step therapy(2 page PDF) continue to affirm that "family physicians using appropriate clinical knowledge, training and experience should be able to prescribe medications and order medical equipment without being subjected to prior authorizations."

The Academy's letter also addressed a section of the proposed rule that would allow insurers' preventive care and wellness services to qualify as quality improvement activities for the individual market medical loss ratio -- the proportion of premium revenue spent on clinical services and quality improvement.

"The AAFP supports MLR policies, as they help ensure health care finances are focused on patient care rather than insurer profits," the Academy said. "With patient care in mind, we encourage CMS to carefully monitor and correct potential unintended consequences with this change."

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