CMS Proposed CY 2024 Physician Fee Schedule Pays for Most Elements of C-TAC’s Assessment

C-TAC has been advocating for a comprehensive assessment for those with serious illness as the way to develop person-centered care plans. We are excited that with this proposed rule, all those components, with the exception of assessing for caregiver burden, now have payment associated with them.

The annual Physician Fee Schedule includes updates on what services will be included and paid for by Medicare Part B. This is where billing codes and their payments are introduced and up for public comment.

This year, several new codes and services are being proposed that could significantly improve the care of those living with serious illness and their families. Many of them are what C-TAC has consistently advocated for, so C-TAC has a lot to support here.

Payment for most of a comprehensive assessment

C-TAC has been advocating for a comprehensive assessment for those with serious illness as the way to develop person-centered care plans. We are excited that with this proposed rule, all those components, with the exception of assessing for caregiver burden, now have payment associated with them:

• Caregiver training services billing codes: While CMS previously paid practitioners to train family caregivers, this was in very limited situations. Now this has been broadened so that a practitioner can be paid to assess whether caregiver training would help their patient achieve their treatment goals and also paid for the time this training takes. While a practitioner has to initiate this process, the actual training can be done by others on the team so nurses, social workers and others can participate. Our only suggestion was that the process include assessing the caregiver for their capabilities before delivering any training.
• Community health integration services referrals: CMS is also proposing separate coding and payment for community health integration services, which would include more things C-TAC has long advocated for: person-centered planning, health system coordination, promoting patient self-advocacy, and facilitating access to community-based resources to address unmet social needs. These are the first Physician Fee Schedule services designed to include care involving community health workers, a role that C-TAC has long championed as well.
• Social determinants of health risk assessments (SDOH) billing codes: Previously, CMS had required practitioners to do SDOH or social risk assessment, but these billing codes recognize that additional payment is necessary to add this important activity to practitioners’ already busy clinical workflows. These codes and payments can be furnished as an add-on to an annual wellness visit or in conjunction with an evaluation and management visit.

Principle illness navigation (PIN) services

These services will help patients navigate treatment for other serious illnesses like the ones that would also benefit from the inclusion of palliative care. These services are also designed to include care involving other peer support specialists, such as peer recovery coaches for individuals with substance use disorder.

The way PIN works is that a practitioner identifies the need for navigation and then works with trained and certified navigators to deliver them on a regular basis. Navigators can be nurses, community health workers, case managers, social workers, etc.

Most encouraging, here’s the text of what these services are to include, which are aligned with C-TAC’s goals.

• Conducting person-centered assessment to understand patient’s life story, strengths, needs, goals, preferences, and desired outcomes, including understanding cultural and linguistic factors.
• Facilitating patient-driven goal setting and establishing action plan.
• Providing tailored support to accomplish treatment plan.
• Identifying or referring patient (and caregiver or family, if applicable) to appropriate supportive services.
• Facilitating and providing social and emotional support to help patient cope with condition, SDOH need(s), and adjust daily routines to better meet diagnosis and treatment goals.
• Leveraging knowledge of serious, high-risk condition and/or lived experience when applicable to provide support, mentorship, or inspiration to meet treatment goals.

Feeling Heard and Understood measure

This proposes adding the palliative-care developed Feeling Heard and Understood measure to the measure sets for the family medicine, internal medicine, and hematology/oncology specialties. We support this and have suggested it be added to other specialty sets as well.

Broadening access to behavioral and mental health services

A law passed last year added marriage and family therapists, mental health counselors, and addiction counselors as Medicare Part B billable practitioners and this proposed rule now provides the regulations for that and also modifies the hospice conditions of participation (CoPs) to add them to hospice interdisciplinary team. CMS seems to think the law mandates that they have to be on hospice teams, but we disagree and said so in our comments.