C-TAC continued its dialogue with the Centers for Medicare and Medicaid (CMS) with comments (download or view here) on the biggest proposed rule of the year, the Physician Fee Schedule for CY2023. This annual rule covers payment for many Medicare services which affect those living with serious illness. C-TAC comments are a way to advocate for this population and advance our policy strategy and we supported many things in the rule:
- Chronic Pain Management and Treatment (CPM) Bundles– Many with serious illness also live with chronic pain and receive poor or uncoordinated care for it. This is also a health equity issue as evidence shows inequities in pain experience and care in communities of color. The proposed CPM bundles would provide a monthly fee for interdisciplinary coordinated care that will also promote advance care planning via a person-centered care plan that includes strengths, goals, clinical needs, and desired outcomes. We suggested that these bundles also include the participation of the family caregiver.
- Request for Information: Medicare Part B Payment for Services Involving Community Health Workers (CHWs)- C-TAC advocates for the use of CHWs in models for those with serious illness and encouraged Medicare to explore ways to further support and promote this role such as the potential payment mechanisms in this proposed rule. Many community health workers come from the local community and so are a helpful resource to deliver culturally appropriate and more equitable care.
- Request for Information: Medicare Potentially Underutilized Services– CMS sought information on those services which could improve quality of care and reduce unnecessary spending and we advocated for, and provided detail on, advance care planning, palliative care, and hospice as such underutilized services.
- Request for Information- Addition of New Consumer Assessment of Healthcare Providers and Systems (CAHPS) for the Merit-based Incentive Payment System (MIPS) Survey Questions – We agreed with addition of questions about whether the care received was unfair or insensitive and a general question about cost or the financial implications of care but noted that CAHPS survey responses have decreased over time and that CMS must address that issue as well.
- Advance care planning added to Group A: New MVPs Proposed for the CY 2023 Performance Period/2025 MIPS Payment Year and Future Years- We were pleased to see that advance care planning has been added to this list of required services and encouraged CMS to consider expanding its use beyond just those with cancer.
Here is what we did not support in the proposed rule:
- Incorrect palliative care exclusion from several measures- We were alarmed to see the proposed new exclusion of those receiving palliative care from measures A.4.Kidney care, 19 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, and D.51 Depression Remission at Twelve Months and said these are all inappropriate. We noted that palliative care seemed to be being equated with hospice, which was incorrect. Excluding those on hospice, who are at the end of life, is appropriate while those receiving palliative care, who could live for years longer, is not. We noted that CAPC defines palliative care as appropriate at any point in a serious illness and that it can be provided along with any curative, disease-modifying treatment and so people on palliative care should still be assessed for kidney health, BMI, or depression when appropriate.
