The most important regulation of the year has just been proposed, the Physician Fee Schedule for 2025. C-TAC always comments on this rule as this is an opportunity to provide input on new Medicare services and billing codes.
We welcome your feedback. The deadline to submit comments to CMS is September 9, 2024. Please contact Marian Grant, C-TAC senior regulatory advisor, at mgrant@thectac.org with any thoughts or comments you’d like us to consider for the following areas, especially the first 2:
- Caregiver Training Services (CTS) – They’re proposing several things:
- New coding and payment for caregiver training for direct care services and supports. The topics of trainings could include techniques to prevent decubitus ulcer formation, wound dressing changes, infection control, special diet preparation, medication administration, and other topics.
- New coding and payment for caregiver behavior management and modification training that could be furnished to the caregiver(s) of an individual patient.
- Telehealth – They would allow the proposed CTS to be furnished via telehealth.
- Requests for Information (RFI) – The Administration often asks for input for future rule making and is now asking about Services Addressing Health-Related Social Needs (Community Health Integration Services, Social Determinants of Health Risk Assessment, and Principal Illness Navigation Services). They’re requesting information on other types of auxiliary personnel (including clinical social workers) and other certification and/or training requirements that are not adequately captured in current coding and payment for these services and how to improve utilization in rural areas. They are also seeking comment about how these codes are being furnished in conjunction with community-based organizations.
One thing we could use member input on: It would be helpful to find out from our CBO members if they’re able to bill those codes. (We’ve heard from some that they can and some that they can’t because of their business structure.) We suspect there may be confusion on CMS’s part about this so would like to provide clarification to them on that.
- Patients’ Experience of Feeling Heard and Understood – We’re delighted that this patient-reported measure, initially developed for community-based palliative care programs, is now being expanded to the measure sets for cardiology, nephrology, family medicine, geriatrics, internal medicines, and oncology/hematology. C-TAC will continue to advocate that it be part of all Medicare measurement programs in our comments on this rule and others.
- Audio-only Telehealth Services under the PFS –The most pertinent of the proposed telehealth changes is to now allow audio-only communication furnished to a beneficiary in their home if the distant site physician or practitioner is technically capable of using an interactive telecommunications system but the patient is not capable of, or does not consent to, the use of video technology. C-TAC has long advocated for this as it recognizes some beneficiaries may not have smart phones or computers to allow for video communication.
- Cardiovascular Risk Assessment and Management – C-TAC has consistently advocated for comprehensive assessments for those with serious illness. This proposed rule adds coding and payment for an Atherosclerotic Cardiovascular Disease (ASCVD) risk assessment service and risk management services.
- Behavioral Health Services – They’re proposing to establish separate coding and payment under the PFS describing safety planning interventions for patients in crisis, including those with suicidal ideation or at risk of suicide or overdose. C-TAC advocates for mental and behavioral health services and this expands access to them.
- Opioid Treatment Programs (OTPs) – CMS is proposing several telecommunication technology flexibilities for opioid use disorder (OUD) treatment services furnished by OTPs including making permanent the current flexibility for furnishing periodic assessments via audio-only telecommunications. This will improve access to these important services.
- Dental and Oral Health Services – Dental services have traditionally not be covered under Medicare but this proposal would add dental or oral examination in the inpatient or outpatient setting prior to Medicare-covered dialysis services for beneficiaries with end-stage renal disease; and medically necessary diagnostic and treatment services to eliminate an oral or dental infection prior to, or contemporaneously with, Medicare- covered dialysis services for beneficiaries with end-stage renal disease.
Call to Action: Contact Marian Grant at mgrant@thectac.org with any thoughts or comments you would like us to consider for these areas before September 9, 2024.
