AMGA Calls for Enhanced Care Coordination in its Comments on Proposed CY 2017 Physician Fee Schedule and Hospital Outpatient Prospective Payment System Proposed Rules

Alexandria, VA –AMGA today submitted written comments on the Centers for Medicare & Medicaid Services (CMS) CY 2017 Physician Fee Schedule and the CY 2017 Hospital Outpatient Prospective Payment System proposed rules.

CY 2017 Physician Fee Schedule Proposed Rule

In its comments regarding the CY 2017 Physician Fee Schedule proposed rule, AMGA stressed the importance of enhancing care coordination and integration through aligned incentives and processes.

“AGMA members are at the forefront of providing integrated and patient-centered care,” said Donald W. Fisher, Ph.D., CAE, AMGA’s president and chief executive officer. “Our comments today offer insight on how CMS can refine its proposals on behavioral health, chronic care management, and accountable care organizations to further care coordination and care integration for patients.”  

AMGA recommended that CMS adopt a lenient view of what services qualify as an “initiating visit” for the appropriate use and billing of behavioral health integration codes. “Patients with mental health needs often seek care for an acute medical problem. We need to ensure the care coordination efforts are as streamlined and accessible as possible,” Fisher said.  

AMGA also recommended that CMS finalize as proposed the beneficiary consent requirements for chronic care management (CCM) services.  “Beneficiary consent, of course, is of vital importance to the doctor-patient relationship,” Fisher said. “Noting consent in the medical record protects patients and simplifies the process for providers.”

AMGA also voiced support for the proposal to add a beneficiary attestation option to the Medicare Shared Savings Program (MSSP) and recommended that it be available for all three MSSP tracks. “AMGA members recognize the importance of patient choice,” Fisher said. “Providing Medicare beneficiaries with the option of choosing their ACO helps patients engage with their provider and also gives the ACO a better idea of its patient population.”  

In addition, AMGA commented on the proposed appropriate use criteria for advanced diagnostic imaging. While this program is required by statute, AMGA advised that it be incorporated into the resource use component of the Merit-Based Incentive Payment System. “Ultimately, appropriate use is about measuring and influencing resource use,” Fisher said.  “Rather than create a separate reporting and measurement structure, CMS should align the appropriate use program with the MIPS resource use component score.” 

AMGA’s written comments on the fee schedule are available here.

CY 2017 Hospital Outpatient Prospective Payment System Proposed Rule

“AMGA is pleased that CMS included in its proposals a 90-day reporting period in 2016 eligible professionals,” said Fisher in AMGA’s comments regarding the CY 2017 Hospital Outpatient Prospective Payment System proposed rule. “As AMGA has stated in previous comments, this change will provide for a smooth transition for both providers and EHR vendors toward a more effective EHR system.”

Fisher added, “AMGA also supports to move toward increased transparency in the hospital outpatient quality reporting. Both providers and patients will benefit from the availability of the performance data.”

AMGA’s full comment letter is available to read here.