WASHINGTON July 11, 2024 – While many of the provisions in the proposed Medicare Physician Fee Schedule could help to strengthen primary care and drive equity and innovation, congressional action is needed to prevent payment cuts and preserve access to telehealth, says the American College of Physicians (ACP). The proposed 2025 Medicare Physician Fee Schedule from the Centers for Medicare and Medicaid Services (CMS) was released Wed. afternoon.
Included in the proposals from CMS is a change to the rules around the new G2211 add-on code that would allow it to be billed on the same day as an annual wellness visit (AWV), vaccine administration, and any Medicare Part B preventive service, a change that ACP has strongly advocated for in the interest of making patient visits more comprehensive and to reduce confusion around the billing for G2211.
“When patients visit their primary care physician, they want to be able to receive care for all of their needs, therefore allowing G2211 to be billed alongside these additional types of visits will help recognize the comprehensive nature of these visits by ensuring that physicians are paid for the full scope of services they are providing” said Isaac O. Opole, MBChB, PhD, MACP, president, ACP “This change is important to ensuring that physicians can apply the G2211 code and realize the best benefits to our patients.”
CMS is also proposing to permanently expand the definition of “telecommunications systems” to cover audio-only telehealth services, bringing them closer in line with policies for audio-video telehealth services. ACP has repeatedly advocated for this change since the very beginning of the COVID-19 pandemic. Audio-only telehealth services are essential to improve access to care, particularly for low-income patients, patients who lack access to broadband, those who have low digital literacy, or others who may not have access to audio-video technology.
The proposed rule also includes several additional provisions that may help to better support the primary care workforce. CMS has proposed a new enhanced program for Advanced Primary Care Management services that could relieve administrative burdens and more appropriately reimburse physicians caring for patients with complex medical and social needs, helping to promote health equity. While CMS is still at the first stage of gathering information and refining these changes, ACP hopes these proposals are a step toward better accounting for the high complexity involved in caring for patients with multi-system illnesses in the primary care setting and strengthening policies that support a longitudinal patient-physician relationship.
“A well-functioning primary care system and strong primary care workforce is the foundation to a high-functioning health care system,” continued Dr. Opole. “Our primary care system has been under tremendous strain in recent years, exacerbated by payments that don’t accurately reflect the value of primary care within our health care system. We hope that the actions that CMS is proposing will begin to improve payments and better support primary care given how critical it is to the health of our patients and the functioning of our entire health care system.”
However, while the proposed rule has many promising provisions, congressional action is needed on several items. The rule contains a 2.8% payment cut for 2025 due to a decrease in the conversion factor that is used to calculate payment rates to physicians and is required by current law to remain budget neutral from year-to-year. This payment cut is on top of a payment cut for 2024 that was only partially fixed through congressional action, a fix that will expire at the end of this calendar year. Congressional action is also needed to extend telehealth flexibilities that were first enacted during the COVID-19 pandemic to improve beneficiaries’ access to care, and which are set to expire at the end of this year.
“We need Congress to step in to stop the payment cut from going into effect,” concluded Dr. Opole. “ACP has been calling on Congress for the past several years to take long-term action to fix this issue. We need a permanent solution from Congress to fix these payment cuts that repeat year-after-year. Physician payments under Medicare have not kept pace with inflation, leading to an effective payment cut over the last two decades that harms the physician workforce and our patients’ access to care.”
Additional initial reactions from ACP include:
- ACP is encouraged by the RFI that CMS included about designing a potential ambulatory specialty care model. ACP has previously proposed a medical neighborhood model as an Advanced Alternative Payment Model (AAPM) proposal that would improve care coordination between specialty practices and the primary care practices who refer patients to them.
- ACP is supportive of CMS’ proposal for new payments to physicians and other health care professionals who are assisting patients at high risk of suicide or overdose, including separate payments for safety planning interventions and post-discharge follow-up contacts. ACP is also supportive of proposals for new payments for the use of digital tools in behavioral health treatments and consultations with behavioral health specialists.
- ACP looks forward to providing feedback to CMS regarding the RFI on the newly implemented Community Health Integration (CHI) services, Principal Illness Navigation (PIN) services, and Social Determinants of Health (SDOH) Risk Assessment.
- ACP is encouraged by CMS’ proposals to establish a new “prepaid shared savings” option for ACO’s with a history of earning shared savings. This allows for investments to better serve beneficiaries in underserved communities and to provide greater financial incentives for ACOs to serve even more beneficiaries from underserved communities via a Health Equity Benchmark Adjustment (HEBA).
***
About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 161,000 internal medicine physicians, related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on X, Facebook, Instagram and LinkedIn.
Contact: Jacquelyn Blaser, (202) 261-4572, jblaser@acponline.org