C-TAC’s dialogue with the federal Medicare program continues as CMS just cited several of our comments in the final Physician Fee Schedule rule. This is confirmation that not only were they reading our comments, but they felt they were important enough to acknowledge in the final rule. They will now contribute to future rule-making in this area.
The Physician Fee Schedule is probably the largest and most important of the annual regulations CMS issues. It covers payment for a range of services, quality measures, and other policies that affect a number of Medicare programs.
This year’s proposed rule included new Chronic Pain Management and Treatment (CPM) Bundles, in recognition of the complexity of managing chronic pain. Despite getting over 150 comments from various organizations on this issue, they specifically acknowledged four of ours:
- Use of a validated pain scale– One commenter stated that pain scales can be beneficial, but they need to be tailored to each person, and that function and quality of life are also important elements to monitor. The same commenter recommended the use of the National Quality Forum’s patient-reported measure, Patients’ Experience of Receiving Desired Help for Pain to achieve this.
- Person-centered care planning– One commenter supported this element of the CPM services and stated that person-centered care planning is not only key for people living with chronic pain, but also for others living with serious illness, and that the person-centered care plan and specifically these elements in the CPM service should become required for people with serious illness.
- Members of the interdisciplinary team– One commenter stated that clinicians such as social workers, pharmacists, and chaplains could be very helpful to address aspects of chronic pain from the incident to billing.
- Caregiver participation for those with cognitive or communication issues- One commenter stated that caregivers and trusted family members are also part of the team providing support to people with chronic pain, and recommended including these individuals in the CPM services, which it noted is especially important for people who have communication or cognitive issues. That commenter stated that caregiver participation for these individuals is especially important as they are often directly affected by the person’s pain and can help in making its perception better, or worse.
They also acknowledged our comments about the proposed exclusion of those receiving palliative care from three measures A.4.Kidney care, D.19 Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, and D.51 Depression Remission at Twelve Months, but disagreed with removing that exclusion: Several commenters were alarmed to see the proposed new exclusion of those receiving palliative care from these measures. Palliative care seems to be equated with hospice, which is incorrect. Excluding those in hospice, who are at the end of life, is appropriate while those receiving palliative care could live for years longer. According to the commenters, palliative care is appropriate at any point in a serious illness and can be provided along with any curative, disease-modifying treatment. The commenters requested that this exclusion be removed as it perpetuates the harmful misconception that palliative care and hospice are the same things when they are not.
We agree that palliative care is appropriate at any point in a serious illness and can be provided with any curative, disease-modifying treatment. It is our expectation that clinicians know the difference between palliative and hospice care and would not equate them. Palliative care is generally provided by an interdisciplinary medical team that focuses on the patient as a whole and would be inclusive of the types of services addressed by this measure as needed. Due to the complexities of care required for this population, clinicians that support patients receiving palliative care may inadvertently not perform well from the aspect of producing quality metrics.
