AAFP responds to proposed rule on 2013 Medicare physician fee schedule

On Aug. 22, 2012, the American Academy of Family Physicians (AAFP) responded to the proposed rule on the 2013 Medicare physician fee schedule. As promised, I am sharing that response with you. Here are some of the highlights; the AAFP:

• Supports the Centers for Medicare & Medicaid Services' (CMS) proposal to create a code for post-discharge transitional care management as a short-term payment strategy; however, the AAFP urges CMS to limit the use of the code to the patient's primary care physician,
• Supports CMS’s intent to investigate potentially misvalued codes, especially in regard to the number and level of post-operative evaluation and management services assumed to be included in global surgical services,
• Urges CMS to not implement the Institute of Medicine recommendations pertaining to geographic practice cost indices, and instead asks that CMS refocus it's efforts on ensuring a properly distributed healthcare workforce that is meeting the demands of a growing beneficiary population,
• Agrees with the proposal to add coverage of ‘‘additional preventive services’’ and supports the proposal to add them to the list of Medicare telehealth services for 2013; however, the AAFP questions several of the proposed payment amounts for these services,
• Supports the CMS proposal to create new criteria for being a successful electronic prescriber for groups of two to 24 eligible professionals,
• Strongly supports CMS’s proposal to streamline the implementation of the Physician Quality Reporting System incentive and reporting programs within the context of the Medicare Shared Saving Program,
• Mostly supports the CMS proposal to begin applying the value-based payment modifier only to groups of 25 or more eligible providers in 2015, so the agency can begin learning how to properly fulfill the statutory requirements; however, the AAFP remains concerned with CMS’s inability to specify the exact amount of the upward payment adjustment because of budget neutrality considerations,
• Fully supports the agency’s proposal to begin Medicare Part B coverage of the Hepatitis B vaccine for high-risk groups, specifically persons with diabetes.

 

The full text of the AAFP response is available online.

The comment period for the proposed rule ends on Sep. 4, 2012. After that deadline, we will have to wait for the final rule to see what CMS decides to do on all of these issues. CMS is expected to release the final rule on the 2013 Medicare physician fee schedule on or around Nov. 1, 2012.