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Rounding the Bend on the Comment Period for #MPFS2019

By Nancy Lundebjerg posted 08-24-2018 02:43 PM

  

We now have a little over two weeks to the deadline (9/10) for comments on the #MPFS2019, so you can probably imagine the fever-pitched pace of our work as we round the bend on our final lap. Here are some highlights from the last week’s worth of action and activity: 

  • What We’re Drafting/Doing
    • In collaboration with our coalition, we’ve put two draft comment letters on the table for consideration. As our thinking currently stands, our first letter—intended for the Centers for Medicare & Medicaid (CMS) specifically—will detail our concerns around the evaluation and management (E/M) coding proposal and make recommendations for moving forward. Our second proposed letter will ask Congress to urge CMS to postpone finalizing any changes to E/M coding and payment while implementing the common sense documentation burden reduction provisions in the Proposed Rule.
    • The AGS is also working on a letter of our own to CMS, which will offer an added layer of insights on the needs and priorities of geriatrics health professionals and the Medicare beneficiaries you serve. More soon as our plans come to fruition.
    • The AGS and other members of our coalition will also be meeting with CMS leadership on Mon., 8/27. We’ll use this important face-to-face opportunity to share our thinking on ways we can move forward together with plans to provide administrative relief while still recognizing the time-intensive nature of your work with older adults and caregivers. 
  • What We’re Discussing
    • Our weekly discussions with AGS leaders, consultants, staff, and collaborators remain laser-focused on the E/M code proposal, but we’re also dedicating time and attention to other critical aspects of the Medicare Physician Fee Schedule Proposed Rule, and to plans for the Quality Payment Program (as you may recall, CMS took the unusual step this year of combining proposed rules for the #MPFS2019 and the QPP). Suffice it to say we’re committed to making sure our comments are as comprehensive as possible.
    • We’re also moving forward in our work with a data consultant retained by our 40+ member coalition. This consultant is helping us model new alternative payment structures, particularly around different options for collapsing E/M codes in ways that might hold promise for reducing administrative burden without jeopardizing the quality of care (or the recognition it deserves). 
  • How AGS Members Can Help
    • At the AGS specifically, we’ve identified 22 AGS/ADGAP experts who we’ve asked to help us with outreach to Congressional leaders who sit on the Senate Finance Committee, House Energy & Commerce Committee, GOP Doctors Caucus, and/or the Republican Policy Committee. The Senate Finance Committee and House Energy & Commerce Committee have jurisdiction over Medicare, so connecting with these leaders in particular is an important step toward ensuring our concerns are taken seriously at the highest levels possible. 
    • The AGS Health in Aging Advocacy Center is now live with two ways you can connect with Congress to tell them how the new E/M proposal would hurt care for older Americans in your state. REMEMBER: These actions are so important, and we’ve work to make them as easy as possible for you to execute.  In particular, if you live in CA, CO, GA, IN, LS, MD, NY, NC, OH, PA, RI, SC, TN, TX, UT, VA, or WY—states where leaders sit on the Senate Finance or House Energy & Commerce Committees—we are hoping you will take action on this request.
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08-27-2018 12:33 AM

I think our comment needs to discuss how this new payment plan would negatively affect the care for cognitively impaired patients and their caregivers. Obviously, this is a major area of focus for CMS and the entire healthcare system.

08-24-2018 04:39 PM

I called the numbers you listed for the two NYS Senators and it rang and eventually went busy. I did get my NYS respresentative's office in DC on the phone and spoke to a 20 some year old who had never heard of the proposed rule.   He was unaware of the issue but when I compared a single illness 65 year old coming for an office visit for an earache with  a multi-morbid, dependent 85 year old who used a cane, had memory loss, and a host of medical illnesses and told him how much more time and thought goes in to the latter, the millenial on the phone seemed to get it.  I think the script should be shortened and the specific proposed rule needs to be referred to in the opening spiel i.e. I am a geriatrician call about the following proposed rule: "............." and would like the representative to call CMS and postpone the deadline for public comment beyond September 9 and the final ruling beyond November so all the stake holders have time to weigh in on this complicated issue.  If this rule is implemented as proposed, it will sound the DEATH KNELL to the care of the elderly by all physicians and specifically the field of geriatrics. 
This proposal is the biggest threat to our field I have seen in the past 40 years. 
Fredrick Sherman MD,MSc, DIC, FACP