C-TAC continues on-going dialogue with the Centers for Medicare and Medicaid Services (CMS) with recent comments on the proposed 2025 Physician Fee Schedule. This is the biggest regulation of the year and the way CMS announces new billable services. Here are our comments on the pertinent parts of this proposed rule:
Caregiver Training Services (CTS) – C-TAC supports establishing new coding and payment for caregiver training for direct care services and behavior management and modification training and to allow them to be done via telehealth. Our additional suggestions are that caregivers should be assessed for their ability and willingness to provide these services and that medical assistants or aides also be allowed to do such caregiver training.
Request for Information (RFI) for Services Addressing Health-Related Social Needs – C-TAC provided these comments:
- Once assessed, any identified needs should be addressed with referrals to appropriate services and a mechanism in place to confirm that these referrals resulted in actual service delivery. Referring people to waiting lists is not the goal but instead to the actual services themselves.
- That many community-based organizations are overwhelmed with service requests and will need infrastructure support to meet the increased demand coming from these new social needs assessments and that CMS and the health system must recognize and address this going forward.
- We noted that while CMS’s only mechanism to establish new services is via the Physician Fee Schedule, these Medicare Part B services all come with patient cost-sharing. We pointed out the irony in charging people to assess their social risks or helping them navigate a challenging healthcare system. While changing this falls outside of CMS’s statutory authority, we asked the agency to be sensitive to the realities of using the Physician Fee Schedule/Medicare Part B as the way to add needed services.
Advanced Primary Care Management Services (APCM) and Cardiovascular Risk Assessment and Management – C-TAC supports these additions and recommended they include palliative care services. For cardiovascular, we shared our work with the American Heart Association (AHA), the “Improving Quality of Life for People with Heart Failure through Integration of Palliative Care Services” initiative and offered to discuss this if desired.
Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood – C-TAC applauds adding this palliative care-developed measure to the cardiology, nephrology, family medicine, geriatrics, internal medicines, and oncology/hematology measure sets and also said it would be appropriate in all Medicare measures sets and for all Medicare programs and will continue to advocate for that.
