Dec. 7, 2022, 8:48 a.m. News Staff — CMS’ recent invitation to health care stakeholders to help the agency improve efficiency and equity offered the Academy a prime opportunity to champion family physicians’ crucial role in public health. In a detailed response to the agency, the AAFP called for stronger investment in primary care, greater commitment to administrative simplification and swift movement to plug the gaps in CMS’ “road map” for the end of the COVID-19 public health emergency.
Answering a question about “well-being and the distribution of the health care workforce,” the Academy emphasized that family physicians cite administrative simplification as their No. 1 need.
“To improve physician well-being and the distribution of the current physician workforce, the AAFP recommends CMS focus on reducing administrative burden, addressing inadequate payment rates by continuously investing in community-based primary care and supporting the primary care workforce,” the letter said. “Administrative tasks are overburdening physicians, reducing the time they can spend treating patients and leading to increased risk of burnout.”
One recent example of this, the letter noted, is the administrative complexity associated with recent surprise billing regulations.
“Since the requirement went into effect, in January 2022, family physicians report that it is adding to their administrative burden, especially for new patients, those with complex medical needs, and those who are uncomfortable sharing their medical records with administrative and clinical staff,” the Academy wrote. “CMS should delay implementation of the Good Faith Estimate provision of the surprise billing rule to allow physicians time to come into compliance and establish the correct mechanisms for providing a good faith estimate.”
The letter further reiterated advocacy calling for improved prior authorization, step therapy and other plan requirements. “While the administrative burden of prior authorizations cannot be meaningfully reduced without comprehensive reform to reduce the volume of requests, the AAFP supports efforts to implement electronic prior authorization as a meaningful first step to streamlining the process.
“Low Medicare physician payment rates are another major challenge family physicians are currently facing,” the Academy added, prefacing recommendations centered on payment.
To accelerate and smooth the transition from fee-for-service medicine to value-based care — a goal shared by HHS and the Academy — the letter urged
“Aligning models across payers and embedding equity as a shared aim, regardless of the patient population, will foster greater physician participation and resource practices more efficiently to ensure all patients receive high quality, affordable, patient-centered care,” the letter said. “The AAFP urges HHS to increase APM participation opportunities, align models across payers and ensure physicians caring for rural and underserved populations can successfully participate in APMs.”
Answering a section of the request for information about waivers, flexibilities and other policies related to the COVID-19 public health emergency, the Academy again urged implementation of a “transparent, intentional and equity-focused approach to ending the PHE and unwinding its associated policy changes.”
Specifically, the letter said permanent telehealth coverage and payment policies should
The Academy repeated a call to regulators to “ensure timely, equitable access to COVID-19 vaccines, testing and treatment across payers and programs.”
“CMS must also provide physicians, beneficiaries, and other stakeholders with at least 60 days of notice before transitioning the purchase of COVID-19 vaccine supplies, testing or therapeutics on to physician practices or beneficiaries,” the letter added. “Finally, we urge CMS to ensure that payment rates for vaccine products and vaccine administration are adequate once the PHE ends or the federal government transfers the vaccines to the commercial market.”
CMS asked for comment on the challenges and barriers patients face across its programs, in which some 145 million individuals are enrolled. The Academy’s response repeated recent advocacy asking the agency to
The Academy realized a Medicare win in October when CMS finalized a rule shortening the gap between Medicare enrollment and the commencement of coverage for many beneficiaries, and increasing the number and scope of Medicare special enrollment periods.
Responding to the RFI’s questions on how to eliminate health disparities, including individual and community-level burdens that impair access to comprehensive, high-quality care, the AAFP made several recommendations, including