ICD-10 is inevitable. Be ready.
As we approach the official start of summer, I’d like to provide updates on some important issues that I believe are likely of interest to each of you. On a personal note, I’m encouraged to see -- with the baseball season entering its third month -- the Washington Nationals are starting to play as well as the “experts” predicted. The long, hot days of summer are where pennants are won and lost to be sure, but I’m encouraged that our nation’s baseball team is currently performing better than Congress, although that is a pretty low bar.
As always, I appreciate your feedback, thoughts, suggestions and occasional criticism of our advocacy work. We here at the AAFP want to make sure that we are representing you in the most effective manner possible, and I believe the interaction generated through this blog, as well as other AAFP vehicles, is critical to our ability to do so. So, keep those comments coming.
As of today, you have 127 days to prepare your practice and staff for ICD-10. With the Oct. 1 compliance date rapidly approaching, I thought it advisable to remind you about the AAFP resources available to assist you and your practice with the transition from ICD-9 to ICD-10. These resources include education materials, tutorials and coding flashcards that cross-walk the top 100 ICD-9 frequently used codes in family medicine practices to the more than 800 corresponding ICD-10 codes that will replace them.
We also continue to encourage all members to conduct end-to-end testing to ensure that you are prepared to make the transition. We are emphasizing testing with your billing clearinghouses, as well as with your payers. These clearinghouses created a tremendous bottleneck during the Form 5010 transition, so to avoid this problem; everyone needs to do their part to ensure this will not reoccur during the ICD-10 transition.
The AAFP continues to communicate with CMS on this issue, and we are expressing our desire to see CMS establish some form of a contingency plan -- especially for solo and small practices -- to ensure claims are paid in a timely manner in the event the conversion from ICD-9 to ICD-10 does not go as predicted.
Annual Wellness Visit
On April 30, the AAFP wrote to CMS expressing concerns with the emerging prevalence of commercial entities offering annual wellness visits (AWVs) to Medicare beneficiaries. In the letter, the AAFP asserted that “the AWV is a tool designed to encourage Medicare patients to engage with their primary care physicians on an annual basis for prevention and detection of illness and we are concerned that there are commercial entities that are subverting that benefit and may be misleading patients.”
The AWV was established as part of the Patient Protection and Affordable Care Act (ACA) and became part of the Medicare benefit package on Jan. 1, 2011. The AAFP actively supported the AWV as part of the ACA, and while we’ve expressed some serious concerns with the complexity of the documentation associated with the service, we continue to see this as a high-value service that connects family physicians with their patients. In the past year we’ve become increasingly concerned that commercial entities that have no desire or intention of providing continuous or comprehensive care have begun promoting their services directly to Medicare beneficiaries.
Unfortunately, it’s come to the AAFP’s attention that patients may be precluded from the benefits of the AWV provided by their family physicians due to services provided by a commercial entity. We see no commitment on the part of these companies to establish a relationship with the patient and it’s clear that they have no intention of caring for the patient after the AWV is provided. This practice has also drawn the attention of the Federal Trade Commission, which shares our concerns that the direct-to-consumer marketing of these commercial entities may contain false or misleading representations or intentional omission of key facts.
The AAFP met with CMS on this issue earlier this month, and we are working closely with key federal decision makers on a solution to this issue. We will keep you posted on our progress.
Give Me More Family Medicine
The Annals of Family Medicine recently published an article highlighting research done by the Robert Graham Center and building on previous research demonstrating the relationship* between primary care, better health outcomes, and lower overall per capita spending on health care.
The authors conclude that, “Increasing family physician comprehensiveness of care, especially as measured by claims measures, is associated with decreasing Medicare costs and hospitalizations. Payment and practice policies that enhance primary care comprehensiveness may help ‘bend the cost curve.’”
This article makes an important contribution to the growing body of literature and demonstrates the value proposition of primary care broadly and family medicine specifically. To view other work produced by the Graham Center please visit their newly redesigned webpage.
* I would have gone with a correlation/causation argument here, but my good friend and co-worker Julie Wood, M.D., would have a field day with my novice mistake.
The AAFP recently joined more than 60 organizations in urging CMS to value, and start paying for, Advanced Care Planning services through two previously established codes. In a May 12 letter, the AAFP and others urged the inclusion of CPT codes 99497 and 99498 in the 2016 Medicare Physician Fee Schedule.
In addition, the AAFP has recently partnered with the Pew Charitable Trust as a collaborator in its Improving End-of-Life Care initiative. This activity brings together several groups who share a common interest in advancing public policy that promotes access to advanced care planning and palliative care.
I anticipate that this issue will become a more prominent part of our national health policy dialogue in the months and years to come. If you are interested in this topic, American Family Physician offers a great collection of resources.
Family Medicine Congressional Conference
The AAFP recently hosted the Family Medicine Congressional Conference (FMCC) in Washington, D.C. This event brings together family physicians, residents and medical students to advocate on behalf of family medicine. This year, more than 200 participants heard presentations from three members of Congress, a senior administration official, six Congressional staffers, and national experts on issues of importance to family medicine. Additionally, participants visited the offices of 160 representatives and 83 Senators to advocate for reforms to our nation’s graduate medical education system.
This event is informative, fun and important to the Academy's success in Washington. I urge you to join us at the 2016 FMCC, which will be held April 18-19 in D.C.
It’s Time to Revolutionize GME -- Not Simply Reform It
“Social entrepreneurs are not content just to give a fish or teach how to fish. They will not rest until they have revolutionized the fishing industry.”
-- Bill Drayton, founder and chair of Ashoka: Innovators for the Public, a nonprofit organization dedicated to fostering social entrepreneurs worldwide
This post isn’t about fishing or the fishing industry. It's about the ability of each of us, individually and collectively, to drive change or, as the author above stated, “revolutionize” an industry.
Physicians aren’t necessarily the first group that people outside of health care think of when pondering professions that drive innovation, but physicians actually are among the most accomplished drivers of change in the world. And family physicians are at the front of that group. Throughout history, physicians have driven innovation in scientific research, revolutionized the practice of medicine, emphasized public health and dramatically improved the quality of life for millions of people worldwide.
As I examined the impact family medicine has had on revolutionizing the health of our nation, I was struck by just how much change our specialty has made. The AAFP has led the charge against smoking and tobacco, we are at the forefront of the obesity crisis, we were one of the first physician organizations to call for universal access to health care coverage -- recognizing that health insurance was a key indicator of health and wellness -- and we led the national effort to maximize vaccination rates.
Today, we continue this leadership through our efforts to modernize the care delivery system; the promotion of payment models that facilitate comprehensive, continuous and connected patient-centered care; and our efforts to place a higher value on the appropriate use of medical services through our work on the Choosing Wisely campaign. These are just a few examples of our efforts and accomplishments, but they demonstrate the positive impact family physicians and the AAFP can have on the health care system and the health of individuals when we organize our voice and speak loudly for change.
Now it is time for the AAFP to harness our energy and drive change in our graduate medical education system.
Today, family physicians from across the nation are gathering in Washington, D.C., for the AAFP’s 2015 Family Medicine Congressional Conference (FMCC). This event features presentations from notable health policy experts, researchers, a senior member of the Obama Administration, and two members of Congress. However, the most important opportunity FMCC provides is a chance for a group of family physicians to join together to drive change and innovation in health care. This year, we will focus our combined energy on revolutionizing our nation’s graduate medical education system.
Although Medicaid, the Veterans Health Administration and some private sources contribute to the training of our physician workforce, the majority of funding comes from Medicare. We spend more than $16 billion annually to train an estimated 120,000 physicians. The challenge for the country as a whole, and our elected officials, is to determine the return we are getting on this investment.
During the past year, there has been an increased awareness that we, as a nation, need to develop a comprehensive strategy on physician workforce. Our national GME policy was developed in the 1960s and continues to rely primarily on a hospital-based model that places a greater emphasis on training a workforce that reflects the needs of a teaching hospital rather than meeting the needs of its community or state. I am not one to diminish the important role teaching hospitals play and the value they add to our health care system. But we need academic health centers and teaching hospitals to play a role in our GME system rather than playing the leading role.
There are two talking points I use repeatedly to drive home the impact of the legacy hospital-based system. First, since 1965 there has been an increase in the number of recognized medical specialties from 10 to 145. Many of these are subspecialties of internal medicine, pediatrics and surgery, but some are new first-certificate disciplines. Second, 71 percent of all medical residents and fellows train east of the Mississippi River, and 60 percent of all residents and fellows are trained in just 10 states. These statistics demonstrate the economic power of GME and how GME finances have been consolidated to a handful of cities and communities.
To put it kindly, the AAFP believes the GME system is in desperate need of change, so we developed and put forth recommendations. In 2014, the AAFP released a report entitled “Aligning Resources, Increasing Accountability, and Delivering a Primary Care Physician Workforce for America.” This policy is thought-provoking by design, but we felt it was time to revolutionize GME -- not simply reform it around the edges.
Our policy proposal calls for limiting GME finances to first-certificate training -- meaning no more federal funding for fellowship training -- and establishes two levels of primary care accountability that hospitals must meet in order the secure their federal GME financing. Additionally, we create a pathway for more federal GME investment in community settings outside the traditional hospital-based system.
This policy remains the foundation of the AAFP’s advocacy efforts regarding comprehensive GME reform and will be the focal point of FMCC. This will not be an easy journey. GME finances are part of the economic fabric of many hospitals, cities and states, and they will not welcome the reforms we have proposed. We, as family medicine, must also recognize that we have a responsibility to change the GME system for the entire physician workforce, not just family medicine. I hope you will join your colleagues who are attending FMCC and lend your voice to driving innovation. Our country needs family medicine to once again be the catalyst of change.
This week, Atul Gawande, M.D., wrote a compelling article titled “Overkill” for The New Yorker about the changes that have occurred in McAllen, Texas, since his July 2009 article entitled “The Cost Conundrum.” Besides being one of the premier medical writers in the world (in my opinion), Dr. Gawande draws some interesting and encouraging conclusions on what has allowed McAllen to go from a high-cost, low-quality health care community to one that is high quality, low-cost. We should be proud of the answer, which is primary care.
I won’t ruin the article for you, but I will tell you my favorite line: “McAllen, in large part because of changes led by primary-care doctors, has gone from a cautionary tale to something more hopeful.”
That's just one more illustration of family medicine as a driver of change.
Final Thoughts on the SGR; A Look Ahead at MACRA
A strange thing happened recently in Washington, the U.S. Congress passed meaningful and impactful legislation in an overwhelming, bipartisan manner -- and the President signed it into law!
On April 16, the President signed into law the Medicare Access and Children's Health Insurance Program Reauthorization Act of 2015 (MACRA) (Public Law 114-10), bringing to a close one of the more frustrating and disruptive health policies of modern times. After 13 years. and 17 short-term fixes at a cost of nearly $170 billion spent, we can now shout from the mountain tops that the SGR IS REPEALED!
A round of applause and a heartfelt thank you to those who engaged with us on this important victory. Although we in Washington like to believe that we can make things happen, we understand fully that it is constituents who drive change, and we thank you for all you have done.
The enactment of this legislation was made possible by historic votes in the House of Representatives and Senate. All told, 484 members of Congress -- or 91 percent -- voted for the bill. AAFP News has an excellent story on the legislative actions and the official AAFP reaction.
For the AAFP, the enactment of this law brings to a close a sustained advocacy campaign that has spanned more than a decade. I want to publicly congratulate AAFP Director of Government Relations Kevin Burke and his team on this great accomplishment and thank them for their relentless pursuit of this legislative objective. It is hard to articulate or quantify the work done by Mr. Burke and his team, but I assure you it was significant.
So the question that likely is on many of your minds is, "what does the law do, and how does it impact me?" Great question. I encourage you to visit the Academy's MACRA resources. This Web page will be your one stop for information on MACRA and the resources the AAFP has available to assist you in your pursuit to implement and comply with the provisions of the law. Start with the Frequently Asked Questions document that provides a top-line summary of the law.
The most important provisions of MACRA are those that extended coverage and access to care for our nation’s children, seniors, and disabled. Extending coverage and access to physician services for these populations was a priority for the AAFP, and we are pleased that they were included.
For our members who see Medicare patients, the most important provision is the one that repeals the flawed sustainable growth rate (SGR) effective immediately. The elimination of this failed payment formula should be celebrated. Family physicians no longer face a lingering threat of losing one-fourth of their income due to the actions, or inactions, of Congress. The SGR not only impacted Medicare payment rates, but also influenced payment rates for commercial insurers who typically pegged their payment rates to a percentage of Medicare. This direct association between Medicare and the commercial insurers meant that a cut initiated by the SGR would reverberate throughout a physician practice. The annual threat of substantial reductions in payments due the SGR was unsettling for physicians.
Starting on July 1, physicians participating in the Medicare program will receive a .5 percent increase in their payments. The .5 percentage increase will continue, annually, through 2019. All physicians participating in the Medicare program will receive these annual updates. Starting in 2019, physicians will have the option of pursuing their payments through an alternative payment model (APM) such as the patient-centered medical home or by staying in the fee-for-service system and participating in the Merit-Based Incentive Payment System (MIPS).
I appreciate that there is anxiety with the transition to APMs and the MIPS program, but remember that this transition does not happen for five years. Furthermore, the law provides resources -- $100 million -- aimed at assisting small and solo practices in the transformation process, ensuring that these important care settings have resources to succeed under the new payment models. This $100 million will be leverage alongside the more than $800 million available in the Transitioning Clinical Practice Initiative (TCPI) launched by the administration last fall. All told, almost $1 billion will be invested in assisting physicians, especially those in solo and small practices, succeed in alternative payment and delivery models.
We also are pleased that starting in 2019 the meaningful use, Physician Quality Reporting System (PQRS), and value-based modifier programs will be consolidated into a single program under the MIPS. This will result in harmonized quality measures and a reduction in the administrative burden of quality improvement programs for those participating in Medicare. The AAFP has long been concerned about the complexity of CMS's programs and the administrative burden they placed on small family medicine practices. This burden often prevents small practices from maximizing opportunities in incentive programs.
This law includes three provisions aimed at assisting solo and small practices remain independent, but also maximizing their ability to achieve full potential in alternative delivery and payment models. Those provisions will allow unaffiliated physicians to be evaluated in the MIPS as a virtual group, helping them lessen the burden of program’s requirements without sacrificing their independence; the Independent Risk Manager model, that would allow independent physicians to share risk without having to affiliate with a large system or accountable care organizations; and provisions that specifically look at ways in which fraud and abuse laws like the Anti-Kickback Statute may unintentionally be making it difficult for physicians -- particularly independent physicians -- to share risk in value-based models.
I know that change is both disruptive and daunting, but I contend that the provisions of this law are both good for family medicine and good for our health care system. The SGR was a truly horrible payment methodology that disrupted practices and perpetuated poor policy-making in Washington. Good riddance to this horrible payment formula, and may we never speak its name again!
Connecting Family Physicians to Communities in Need
A quick update: As reported in my previous post, the House of Representatives approved the Medicare Access and Children’s Health Insurance Program Reauthorization Act (H.R. 2) on March 26 by a vote of 392-37. The U.S. Senate is expected to consider the legislation this week. We continue to urge members to contact their Senators and urge them to support this important legislation.
In a world with good and bad government programs, the National Health Service Corps (NHSC) has to rank near the top of the good list.
Established in 1970 as part of the Emergency Health Personnel Act, the NHSC was designed to address growing physician shortages in primary care specialties and the decreasing numbers of primary care physicians practicing in underserved communities. Its mission was simple, “improve the delivery of health services to persons living in communities and areas of the United States where health personnel and services are inadequate.”
The AAFP has long viewed the NHSC as a central component of the nation’s primary care workforce strategy. We adopted our first policy regarding the NHSC in 1974, and it has been consistently reaffirmed by the AAFP Congress of Delegates since its initial adoption. That policy states clearly that the AAFP “supports the objectives of the National Health Service Corps” and that we will “assist the Corps in making information available to family medicine residents regarding practice opportunities and benefits in the Corps.”
The Academy continues to honor this directive through our advocacy and education activities. We are especially pleased that the NHSC, through the Medicare Access and Children’s Health Insurance Program Reauthorization Act (H.R. 2), would be funded for an additional two years. The funding extension is strongly supported by the AAFP and would allow the Corps to continue its mission of placing family physicians in underserved communities. Without such an extension, funding for this vital program is scheduled to stop on Sept. 30.
In 1972, the NHSC placed an initial 180 volunteer physicians in 100 communities. Also in 1972, the Emergency Health Personnel Act Amendments established the NHSC Scholarship Program. This program awarded a full scholarship -- measured by tuition, fees, and stipends -- based on a commitment on the part of the scholar to serve in an underserved community. The NHSC continued to place volunteers in underserved communities between 1972 and 1977 while the first class of scholars completed their residency training. In 1977, the first class of NHSC scholars began their service.
In 1987, the NHSC was enhanced though the establishment of the NHSC Loan Repayment Program. This program afforded primary care physicians incremental annual payments that were applied against their student loans in return for service in an underserved community. The loan repayment program was important to the growth and reach of the NHSC because it allowed communities to immediately meet their health care needs, as opposed to waiting for a physician to complete his or her training through the NHSC scholarship pipeline.
Today, more than 9,000 physicians, dentists and other primary care professionals are participating in the program. Collectively, they provide care to more than 9.5 million people. All told, more than 45,000 primary care physicians, dentists and others have participated in the program, delivering health care services to millions of patients in our nation’s most vulnerable communities.
From early pioneers, like David Cutsforth, M.D., and David Grube, M.D., to the current generation of NHSC participants, like Brian Freeman, M.D. and Christin Donnelly, M.D., thousands of family physicians have participated in the NHSC program during the past 45 years. Through their service, millions of patients had access to health care they otherwise might not have had.
Future generations of family physicians will continue this proud tradition of service and will impact positively the lives of millions of people who reside in our nation’s health professions shortage areas (HPSAs) through participation in the NHSC program. For the thousands of family physicians who have participated in this program, we thank you for your service. For the current generation of medical students and family medicine residents, we urge you to consider the NHSC as a means of assisting with the financing of your education, but more importantly as a practice opportunity that will impact individuals who otherwise may not have access to your skills and compassion.
The AAFP values our relationship with the NHSC and is committed to securing adequate and stable funding for the program so that it may continue to improve the lives of people living in our most vulnerable communities.
In a 5-4 decision, the U.S. Supreme Court ruled in the Armstrong v Exceptional Child Centers Inc. that physicians and other health care providers could not sue states for higher payments under the equal access provisions of the Medicaid Act. The decision by the Supreme Court overturns a ruling issued by the 9th Circuit Court of Appeals. The equal access provisions of the Medicaid Act requires that states accepting federal Medicaid funding establish payment rates at levels that ensure access to care for beneficiaries.
The AAFP joined other physician organizations in submitting an amicus brief to the Supreme Court in support of the 9th Circuit decision. The majority opinion noted that physicians have administrative remedies for low payment rates. The opinion went on to suggest that “plaintiffs must first seek relief through CMS first before instigating legal action.”
March Madness Goes Into Overtime
Last week, in an overwhelming display of bipartisanship, the House of Representatives approved the Medicare Access and CHIP Reauthorization Act (H.R. 2) by a vote of 392-37. After 12 years of temporary patches, the House stated that the failed sustainable growth rate (SGR) formula should be eliminated from the Medicare program.
The AAFP issued a statement that praised the House for its overwhelming support of H.R. 2 and called on the Senate to follow the House’s lead and pass the legislation prior to adjourning for the annual spring recess.
Upon House approval, the AAFP swiftly informed members through an AAFP News article and direct emails to our state chapters and members regarding the House vote and called for aggressive advocacy targeted at the Senate. AAFP members and our state chapters answered the bell and made several phone calls to key Senate offices urging immediate action. AAFP President Robert Wergin, M.D., was in Washington when the House voted on March 26 and personally called several Senators during the course of the day, urging them to pass H.R. 2 prior to adjourning.
Unfortunately, the Senate didn’t share the House's sense of urgency and failed to consider the legislation prior to adjourning. The Senate is scheduled to return April 13. In a positive sign, Senate Majority Leader Mitch McConnell, R-Ky., said before the Senate adjourned on March 27, “It is encouraging this [H.R. 2] passed the House with such a large bipartisan majority, and I want to assure we’ll move to it very quickly when we get back. … I think there is every reason to believe it’s going to pass the Senate by a very large majority.”
In a statement the Academy expressed its disappointment that the Senate failed to follow the House’s lead and protect Medicare patients and children’s access to care prior to adjourning. We called on senators to promptly approve H.R. 2 upon their return, thus preventing disruptions in care for millions of Medicare beneficiaries.
The Senate’s failure to act on HR 2 prior to adjourning means that the 21 percent cut scheduled for April 1 will take effect. As a result, all services provided by Medicare participating physicians on or after Wednesday, April 1 – continuing until the Senate passes HR 2 and the law is enacted into law by the President – will be subject to the 21 percent cut. CMS has instructed its carriers to “hold,” for 10 business days, any claims for services provided on April 1 and beyond, until legislation can be passed and signed into law that reverses the 21 percent cut. The 10-day hold means that April claims will be held through Tuesday, April 14. Under current law, no claims can be paid sooner than 14 calendar days from their receipt, so this hold will have a minimal impact on Medicare remittance in the short-term.
However, the claims hold period does complicate billing for co-payments and claims reconciliation. Family Practice Management has created a resource, “Preparing for a Medicare Fee Cut,” that is designed to help you and your practice prepare for any reductions in revenue that may occur as a result of the cut.
Since it is spring, I am going to offer a golf analogy. It is often stated that the Masters is “won or lost on the back nine on Sunday afternoon.” Well, my friends, it’s Sunday, and we are on the back nine of the SGR issue. The only remaining question is whether we win or lose. I want to win, and I believe you do as well. The AAFP has engaged you on this issue multiple times during the past two months, and you have responded. The advocacy engagement of our members is one of the reasons 392 members of the House voted to repeal the SGR. We thank you for all of your great work, but we need more.
Between today and April 13 you need to communicate your strong support for the House-passed Medicare Access and CHIP Reauthorization Act (HR 2) to your senators. Please visit our Speak Out page, and send a letter to your Senators. After you send a letter, call your Senators. The AAFP has a toll-free phone system that allows you to do this conveniently. Simply call (866) 629-5269, provide your state, and you will be connected to your senate offices. Once connected, simply tell them you are a family physician practicing in their state, and you urge them to vote yes on HR 2 when it is considered by the Senate. That’s it – simple. Call them every day. Tell your colleagues to call. Tell your patients to call.
The AAFP has worked tirelessly on this issue for more than a decade, and with your continued help, we can finally repeal the flawed SGR formula. Victory is in sight, but we must stay focused and engaged for these final days.
SGR Deadline Looms; ACA Faces SCOTUS Challenge
In my previous In the Trenches post, I implored (some might say begged) you to write a letter to your members of Congress urging the full repeal of the flawed sustainable growth rate formula. I want to thank those of you who took the time to communicate with your elected officials. For those who haven’t yet sent a communication, I continue to urge you to do so.
A full repeal and replace bill is expected to be considered any day now, and your elected officials need to hear from family physicians who support this legislative proposal. This is not a test, this is real. And we need your help.
I urge you to watch this passionate communication from AAFP President Robert Wergin, M.D., and then Speak Out.
ACA Turns 5. Will It Turn 6?
On March 23, the Patient Protection and Affordable Care Act (ACA) will celebrate its fifth anniversary. This date is a cause for celebration for many in our country and a reminder of one of the darker days in our nation’s legislative history for others.
Regardless of political affiliation, there was a strong bipartisan consensus in early 2000s that our health care system was broken, wasteful and a drag on individual and business economic growth. It is often difficult to recall the context in which policy decisions were made, especially in a society that consumes and disregards information at such an alarming rate. This is why I think it is important that we look back at the decade prior to the enactment of the ACA to remind ourselves of the challenges we faced as individuals and as a country.
In 2001, 39.8 million people, or 14.1 percent of the population, were uninsured. By 2006, the number of uninsured had increased to 47 million or 15.8 population of the population. In 2010, the year the ACA was enacted, there were 49.9 million people uninsured or 16.3 percent of the population. Ponder those numbers for a moment.
According to the Kaiser Family Foundation, in 2000, a family of four paid an average of $6,438 for its health insurance. By 2010, this same family paid more than $13,000 for the same policy. Insurance costs for individuals also increased dramatically going from an average of $2,471 in 2010 to more than $5,000 in 2010. Between 2000 and 2010, health insurance costs increased 159 percent, and wages increased 42 percent. As a result, the number of uninsured and underinsured exploded.
By 2008, both presidential candidates and a large swath of the U.S. Congress were calling for comprehensive health reforms. In 2010, Congress delivered a bill to President Obama, and he signed it – with cheers of jubilation from most corners of society (and over loud cries of opposition from others). In 2011, the law survived a Supreme Court challenge and implementation began. It didn’t go so well, but it began.
So where are we today? In the latest open enrollment period, 11.4 million people enrolled in an insurance product sold through a state or federal Health Insurance Marketplace. Medicaid expansion, in those states where it has been implemented, has expanded health care coverage to more than 7 million people.
Although it would seem that a fifth anniversary would signal stability, the ACA is far from stable. On March 4, the Supreme Court heard oral arguments in King versus Burwell, which seeks to establish that the tax subsidies created by the ACA and aimed at assisting low-income individuals in the purchase of health insurance, are not applicable to individuals purchasing an insurance policy in the federal Health Insurance Marketplace. The plaintiffs in the case argue that the law only allows such tax subsidies for individuals who purchase a health insurance policy through a state-established Health Insurance Marketplace.
The immediate and real-world implication of a ruling in favor of King is that 13.4 million people would become uninsured immediately. Now, there are pathways for those individuals to retain their health coverage, but those pathways require action by Congress, but I wouldn’t look for white horses to come galloping to the rescue. It also would send the insurance market in many, if not all, state into chaos. Neither of these events is good for our health care system.
The AAFP has advocated for universal health care coverage since 1989 when the Congress of Delegates approved a resolution entitled “Health Care for All: A Framework for Moving to a Primary Care-Based Health Care System in the United States.” With few modifications, this policy has stood the test of time. At the core of this policy is the following statement, “Ensuring that all people in the United States have health care coverage is essential to moving toward a healthier and more productive society.” This policy is central to the AAFP’s advocacy efforts and, in my opinion, to family medicine.
Each of you understands the importance of health care coverage because you see it every day in your practices. Of course, people with health insurance sometimes still face challenges accessing health care services because insurance companies aren’t always the most helpful partners. But despite some administrative burdens, individuals with health care coverage have better opportunities to be healthy than the uninsured.
Decades of research shows that there are two leading drivers of a quality health care system: health care coverage and a continuous relationship with a physician, most often a primary care physician. These two indicators, when combined, have demonstrated the ability to improve the health of individuals and do so in an economically efficient manner. Regardless of your political stripes, 13.4 million uninsured is an undesirable outcome.
SGR: Time to say goodbye to a familiar foe
In politics, as in many things in business and life, the hardest tasks often are those that come at the end. This is where we find ourselves on a familiar and extremely frustrating issue -- the Medicare sustainable growth rate (SGR).
In less than 30 days, Medicare will implement the largest and most damaging payment cut in its history as a result of the flawed and failed SGR formula -- unless Congress intervenes. Should Congress fail to act and this draconian cut is realized, many of you will face trying questions about your future participation in the Medicare program, and Medicare beneficiaries across the nation could face challenges in securing access to care.
The AAFP is focused on preventing both of these scenarios. In fact, we are committed to ensuring you and your Medicare patients never have to face this dilemma again. Last week the AAFP Board of Directors was in Washington advocating on your behalf. Now, we need your help. We need you to raise your voice and advocate for your patients, yourself and your colleagues. I will tell you how later in this post. For those that can’t wait, please go to Speak Out, and send a letter to your representative and senator today!
During the 113th Congress, a bipartisan group of representatives and senators introduced the SGR Repeal and Medicare Provider Payment Modernization Act of 2014. This legislation was supported by the AAFP and endorsed by an overwhelming majority of physician and health care organizations. Additionally, it secured the support of the two House committees and one Senate committee with jurisdiction over the Medicare program.
The support for this SGR repeal legislation was bipartisan and solid. Sadly, negotiations on how to finance the legislation prevented its consideration by the full House and Senate, and -- for the 17th time in 12 years -- Congress enacted a safe, comfortable and cowardly short-term patch.
The AAFP continues to strongly support this proposal. On March 2, we wrote to House and Senate leaders urging the immediate enactment of this policy.
There are plenty of provisions in this proposal that will cause some to gnash their teeth, but on the whole, this proposal is a significant step in the right direction and is good for family medicine. The proposal not only repeals the flawed and failed SGR formula, it also puts in place a path for the implementation of new delivery and payment models that transition our health care system from an episodic and volume-driven model to a longitudinal and quality-driven model. Additionally, it provides family physicians practicing in advanced practice models enhanced payments and a simplified administrative burden.
We applaud the work that led to this policy and work that is ongoing to pursue its enactment into law. The 17 short-term fixes Congress has enacted have cost the nation more than $169 billion. We urge Congress to move beyond the short-term, stop-gap measures that have become the accepted course of action on this issue.
The Medicare program relies on access to a robust primary care physician workforce, yet payment and regulatory policies make it difficult for each of you to provide care to your patients. Since the establishment of the SGR, physician payments have fallen greater than 20 percent below medical inflation. These stagnant payments have come during the same period that Congress piled more than 20 rules, regulations and new programs on you. Today, each of you are asked to comply with a complex web of regulations that prevent you from focusing on patient care and push you to a level of frustration that elicits some non-printable comments.
Family physicians are not only providers of essential health care services; they also are small businesses that create well-paying jobs and contribute to the economic viability of communities small and large. Family physicians are economic engines for your communities. On average, each of you employ five full-time employees and directly produce nearly $1 million in economic activity. Collectively, family physicians nationwide employ more than 350,000 people and generate more than $46 billion in economic activity. It is improbable to believe that any small business can endure a 21 percent reduction in its revenue and an explosion in mandatory compliance to regulations.
Your frustration with this issue is understandable and I don’t blame you for being annoyed that I am asking you to once again take action in support of repealing the SGR. However, I am asking for you to take action, and I am asking you to channel those 12 years of frustration at your elected officials. I am asking you to SPEAK OUT on behalf of your patients. I am asking you to SPEAK OUT on behalf of yourself and your practice. I am asking you to SPEAK OUT on behalf of your colleagues. Finally, if it helps, I am asking you to SPEAK OUT simply as a means of venting your frustration. I don’t care which of these factors motivates you to write a letter, but I urge you to do so.
Meaningful Use and PQRS Extensions
On Feb. 25, CMS and the Office of the National Coordinator (ONC) announced an extension in the reporting and attestation periods for eligible professionals participating in the EHR Meaningful Use and PQRS programs. Practices now have until March 20 to complete their attestations and reporting. The AAFP worked closely with CMS and ONC on this extension and is pleased that they made a decision to extend the reporting periods. We were concerned that widespread winter weather events would prohibit many family physicians from meeting the deadlines.
Creating A Medical Home is About Improvement, Not Checking Boxes
My medical home has a first name, and it’s not NCQA.
Eight years ago this month, the AAFP joined with the American Academy of Pediatrics (AAP), the American College of Physicians (ACP), and the American Osteopathic Association (AOA) to publish the Joint Principles of the Patient-Centered Medical Home (PCMH). The Joint Principles were grounded in the AAP’s work on children’s medical homes established in 1967 and supported by the AAFP’s 2004 Future of Family Medicine project -- which called for every individual to have a medical home -- and ACP’s work to develop an “advanced medical home,” which started in 2006.
Through a process that originated in 2006, these four organizations developed a set of seven principles that described the characteristics of a PCMH. Those seven principles call for each patient to have an ongoing relationship with a personal physician in a physician-directed medical practice and team. The physician and the team are responsible for providing all the patients’ health care needs, coordinating care across all elements of the health care system, expanding access, and providing patient-centric care. The final principle states that payment should appropriately recognize the added value of PCMH to patients, caregivers and physicians.
The four organizations mentioned above, along with IBM, also founded the Patient-Centered Primary Care Collaborative (PCPCC), and the seven principles continue to serve as the North Star for that organization. The Joint Principles have been cited in numerous academic articles, the Congressional record and functioned as the substance of several state and federal laws and regulations. Furthermore, they are the guiding values of hundreds of PCMH programs run by insurance plans across the nation.
The PCMH, unlike other practice models -- such as managed care -- was created by physicians and not by others for physicians. The Joint Principles embodied an approach to the practice of medicine that many physicians had used throughout their careers. In many ways, the PCMH reflected how physicians wanted to provide care for their patients and not how someone else felt they should do so. It was organic and originated from the physicians who would ultimately practice in the model.
The enthusiasm surrounding the PCMH was palpable in the years following, and many family physicians saw the PCMH and the Joint Principles as the path forward to a better health care system focused on patients and supportive of physicians' sincere desires to “get off the hamster wheel.” The AAFP and our partner organizations were thrilled that the movement was based on a set of achievable characteristics that appealed to physicians in all practice settings.
In recent years, ownership of the medical home has moved from the physicians and physician organizations that created it towards the quasi-government agencies that recognize the practices. As a result, physician enthusiasm for the model has waned -- to put it mildly.
Third-party recognition is important if it is supported by a business case in your practice or local market, meaning there are payment incentives available. The Joint Principles contained a recommendation that “all practices should go through a voluntary recognition process by an appropriate non-governmental entity to demonstrate that they have the capabilities to provide patient-centered services consistent with the characteristic of the PCMH as articulated in the Joint Principles.” However, we never thought that this service would be provided only by, let’s say, the National Committee for Quality Assurance (NCQA). We envisioned a recognition process whereby an insurance plan or collection of insurance plans, a quality improvement organization, or a Medicaid program that was offering enhanced payments for PCMH would verify practice capabilities.
The AAFP remains agnostic on PCMH recognition programs. If you think your local market or practice business plan would benefit from recognition, then discuss with your local payers and/or pursue collaboration with any of the organizations that provide PCMH recognition programs such as the Accreditation Association for Ambulatory Health Care (AAAHC), URAC, the Joint Commission, or the National Committee for Quality Assurance (NCQA). The process of becoming a recognized medical home should be collaborative and focused on the characteristics of the Joint Principles. It should not be a collection of chart extractions, screen captures and checklists. It should be focused on practice and performance improvement. It should not be a product you purchase -- or repurchase every two or three years.
In short, don’t consider PCMH practice redesign and NCQA designation as synonymous. This line of thinking has taken a practice redesign and patient care model once celebrated by primary care physicians and turned PCMH into a dreaded phrase in primary care. I encourage every family physician to transform your practice based on the principles of the PCMH. And, you should consider third-party PCMH designation if that is beneficial to your practice, but please free yourself from thinking that NCQA recognition is the only organization that can recognize you as a PCMH because there are others.
The most important activity for family physicians is providing high quality care to your patients, and I believe that practice transformation consistent with the characteristics of the PCMH will help you in this endeavor by focusing your practice on process improvement, quality improvement, team-based and patient-centric care, and reform at a pace that benefits your patients and your practice. The AAFP has a variety of resources to assist you. Our approach is to meet you where you are and assist you in transforming at your own pace. The PCMH Planner is the perfect tool because it has a full complement of resources and allows you and your practice to move at a comfortable pace.
The Backbone of American Health Care: Serving Small Practice Family Physicians
One of the most common questions asked on this blog, and other AAFP mediums is, “what are you doing for small practices?” The answer is “a lot.”
The AAFP is committed to providing services and products to all family physicians, and the Academy strives to be your first and most trusted source for information and resources. Family medicine is a large and diverse discipline, and our goal is to meet your professional and practice needs, regardless of your practice size, type, location or employment status. Our members are all equally important to the AAFP, and we want to assist you in achieving professional success, so you can concentrate on delivering high quality care to the millions of patients you care for collectively.
The solo and small physician practice remains the bedrock of our nation’s health care system. Although much has changed, the presence of a family physician in communities large and small has remained consistent. Today, more than 70 percent of family physicians practice in groups of five or less. Although some of these physicians may be employed or integrated into larger delivery systems, they remain a solo or small group practice, striving to provide the highest quality of care to their patients.
Although change is inevitable, the volume and pace of change can be overwhelming. In the past decade, family physicians have seen the implementation of the Physician Quality Reporting System (PQRS) and numerous quality reporting programs operated by private payers; the establishment of meaningful use criteria that govern the way in which you must use your electronic health records to earn an incentive and avoid a penalty from Medicare;an explosion in prior authorization and appropriate use criteria programs; new requirements on physician authorization for diabetic supplies and durable medical equipment and more.
You have been asked to do this at the same time that you have seen revenue decrease as a result of a flawed Medicare physician payment formula and continued squeezes on payment by Medicaid and insurers. Each of you know the challenges of meeting these demands, suggestions, and mandates better than I. But I think it is important for you to know that we hear you, and the Academy is working hard to help.
Recognizing the importance of solo and small group physicians to our health care system and the numerous challenges these physicians face, the AAFP formed the Independent, Solo, Small Group Practice Member Interest Group. This group is an important voice for solo and small practices, providing insights and feedback to the AAFP on practice and advocacy issues. If you are a solo or small group practice family physician, or simply someone who supports the practice model, I encourage you to participate in this important group. Not only can you provide input to the AAFP but you can also share best practices with your colleagues who share similar issues and concerns.
In addition to the member interest group and our advocacy in Washington, D.C., and state capitols, the AAFP has amassed volumes of resources for solo and small group practices. You can find these resources on the AAFP’s practice management webpage. I also encourage you to utilize resources from Family Practice Management (FPM). These resources provide information and tools related to many of the issues facing your practice.
I would like to highlight resources the Academy has developed in five key areas: PQRS, meaningful use, practice management, ICD-10 and practice transformation.
Physician Quality Reporting System
There are two primary incentive/penalty programs for family physicians participating in Medicare -- PQRS and meaningful use. PQRS includes a bonus payment for eligible professionals who report data on quality measures for covered services provided to Medicare Part B fee-for-service beneficiaries in 2014. However, the program also implements penalties starting in 2015 for performance year 2013; potential penalties related to the 2014 performance year are effective in 2016. Time is running out to report 2014 PQRS data. You have until 5 p.m. EST on Feb. 26 to submit your 2014 data via the PQRSWizard referenced below. Doing so will help you earn a 0.5 percent bonus for 2014 and avoid a 2 percent penalty in 2016.
The Medicare Electronic Health Record (EHR) Incentive Program provides incentive payments to eligible professionals who demonstrate meaningful use of certified EHR technology. The cumulative payment amount depends on the year in which you began participating in the program. However, penalties will start this year for physicians who do not demonstrate meaningful use in 2015. Compliance with this regulation is one of the top concerns raised by solo and small group physicians.
Although the AAFP is working tirelessly to change the regulation to make it more achievable and less onerous, we recognize that you need assistance in meeting the requirements of meaningful use. The AAFP has compiled a menu of services and products aimed at assisting your efforts to avoid the penalties.
The PCMH Planner has an excellent module aimed at achieving meaningful use. For less than $100, you can receive top-shelf guidance on meaningful use 1 and 2, as well as a step-by-step guide to practice transformation.
One of the most important objectives for any practice, but especially small practices, is establishing predictable revenue. Although the most important step to achieving this goal is the elimination of the flawed Medicare payment formula and the sustainable growth rate, there are practice management resources that can help. The AAFP has developed the Five Key Financial Metrics online education modules to assist you in evaluating and establishing sound business practices for accounts receivable, accounts receivable greater than 100 days, adjusted collection rate, denial rate and average reimbursement rate. These online tools summarize steps you can take to improve the financial health of your practice.
FPM toolbox also is a tremendous resource for your practice. FPM has articles and tools on a variety of topics, including billing, collections, claims processing, financial management, coding and documentation, staffing and many other important topics.
Compliance with the upcoming ICD-10 requirement is a concern for all physicians, especially solo and small practices. The Academy supported delaying implementation of these codes, but we recognize the need to provide resources because the transition will become mandatory Oct. 1. The AAFP has several resources designed to provide guidance on this important and complex issue. Our ICD-10 resource page features free information and low-cost products and services to assist your practice in the transition to ICD-10. In addition, FPM has published 11 detailed articles about how to code with ICD-10.
Practice transformation and process improvement is another area where small practice physicians often feel overwhelmed. To assist practices, the Academy has developed a variety of services and products to help. Whether you are interested in becoming a patient-centered medical home, joining an accountable care organization, or transforming your practice into a direct primary care practice, the AAFP has resources to assist you in your practice transformation goals. Our objective is to provide you information and tools that allow you to move at a pace that is most suitable for you and your practice.
I want to thank those who remind me and the AAFP of the unique needs of solo and small group practices. Your messages drive innovation and motivate our team to identify, create, and distribute products and services that enable you to be successful in your practice -- no matter how big or small. I hope you now have a better understanding of the products, services, and resources we have that are designed to assist solo and small practices. Our staff has worked hard to make certain that we are meeting your unique needs. However, if there are other resources and tools needed, please let us know. We welcome your insights and appreciate your recommendations.
Finding a Way Forward, Together
I recently had the opportunity to join HHS Secretary Sylvia Burwell for a small event where she outlined the visions, goals and objectives of the department for the final two years of the Obama Administration in a speech entitled, “Common Interests; Common Ground – Finding a Way Forward, Together.” Although these types of speeches are common in Washington, D.C., this time of the year, the subject matter discussed was quite refreshing.
Burwell expressed a desire to identify areas of common interest with Congress and, as is noted in the title of her speech, “find a way forward, together.” She focused on goals that were achievable versus ideological, and she promoted issues that historically have had strong bipartisan support. She is not naive. She understands the political challenges presented by the Patient Protection and Affordable Care Act. However, she also understands that there is capacity for meaningful work to occur on health care issues while the political debate about the ACA continues. She framed her remarks in the form of an invitation or an open call to interested parties inside and outside the federal government to work with the administration on a set of common goals.
I was struck by the level of commitment the AAFP has made to each of the priorities articulated by the secretary. Family medicine remains at the forefront of innovation in science, medicine, quality improvement, patient engagement and health care delivery. We are the physician leaders that advocate for patients and drive change in our health care system. Although the specifics of HHS policy objectives may differ from those of the AAFP, the areas of focus are aligned. These are areas that beckon for policy and advocacy work as a means of improving our health care system and the health of our population. The goals articulated by the secretary focused on six large themes:
- Medicaid expansion;
- A health care system that’s better, smarter and healthier;
- Reducing substance use disorders and overdose deaths;
- Global health security;
- Leadership in science and innovation; and
- Building an innovation economy.
I would like to expand on four of these themes and share how family medicine is leading on each.
Today, roughly 70 percent of family physicians participate in Medicaid. With the exception of pediatricians, that level of participation is not seen by other physician specialties. Twenty-seven states and the District of Columbia have expanded their programs. The AAFP and our state chapters continue to advocate for the expansion of Medicaid in the remaining 23 states as a means of providing health care coverage to low income individuals and families. As I have stated many times in this blog, there are two common indicators of improved health for individuals -- health care coverage and a continuous relationship with a primary care physician, most commonly a family physician. The AAFP believes that there are many pathways to expanding Medicaid that promote greater access and protect the integrity of the program, while being flexible to account for variations in each state's population and health care needs.
The AAFP has numerous policy objectives aimed at improving Medicaid, specifically the need to ensure adequate networks of participating family physicians are available to Medicaid patients and that the program has a payment model that compensates family physicians fairly for services provided. We will continue to pursue these specific policy objectives with Congress and the administration while also continuing our work to expand access.
A Health Care System That’s Better, Smarter and Healthier
The AAFP has a long history of leadership in quality improvement as well as delivery and payment system reform. This commitment to a better health care system is as old as the discipline itself. This past year, the AAFP and the other family medicine organizations announced a major new initiative -- Family Medicine for America’s Health -- that is aligned with the goal of a better, smarter and healthier health care system. The work of the campaign will focus on six strategic objectives: practice transformation, payment reform, workforce development, improved technology, family medicine research and patient/caregiver engagement. We have already initiated conversation with the administration and Congress on this work, and we look forward to working collaboratively with them and state governments on this campaign during the next five years.
Reducing Substance use Disorders and Overdose Deaths
The challenges presented by substance abuse disorders and prescription drug abuse are far too common in our country. Family physicians are on the front lines of this health care and public policy issue. As the percentage of the population using powerful drugs for chronic pain and other conditions rises, so does the incidence of abuse and overdoses. The AAFP is actively engaged in finding solutions to pain management and prescription drug abuse problems. Our strategies can be found in our policy paper, “Pain Management and Opioid Abuse: A Public Health Concern.”
The AAFP also has made this issue a focal point of our advocacy efforts at the federal and state levels. This past November, the Academy hosted a discussion at our State Legislative Conference that brought together national experts to share strategies on how to best approach these challenging issues with legislators. We also have developed resources aimed at educating patients on the dangers of prescription drug abuse and how they can work with their family physicians to prevent or stop prescription drug abuse.
Global Health Security
This past year saw public health crises associated with respiratory virus, influenza, several antibiotic resistant bacteria and Ebola. The Ebola epidemic gripped our national attention and shed light on the importance of a strong primary care and public health system. Family medicine again was a leader for the public, physicians, elected officials and foreign aid agencies. Time magazine named the “Ebola Fighter” their 2014 Person of the Year. Family medicine should be proud that many of those recognized are your colleagues. Their contributions continue to have a positive impact on the lives of millions of people around the world.
Family physicians have always been at the front edge of public health crises, but this past year amplified just how committed family physicians are to this responsibility both domestically and internationally. In December the AAFP published a new position paper on the integration of primary care and public health. The paper recognizes the importance of strengthening community health infrastructure with a call to action to our members along with our public health colleagues.
A New Year, a New Congress and New Opportunities for Family Medicine
Happy New Year! Today marks the start of the 114th Congress. For the first time since 2006, Republicans control both the House of Representatives and the Senate. It also marks the final two years of President Obama’s administration.
If history is any indication, the combination of a divided government and a lame duck president may lead to more productivity than many are predicting as Republicans focus on demonstrating the ability to govern, and the President strives to solidify his legacy.
A lingering question for the AAFP is how will health care policy fit in these two distinct agendas?
It is important to remind ourselves that all activities in Washington during the next two years will be conducted with an eye on Nov. 8, 2016 -- the date of the next presidential election. As we prepare for the upcoming legislative session, I want to outline the Academy's advocacy priorities as a means to inform you about where the AAFP plans to focus its attention during the next two years and as an invitation for you to comment on other areas where you would recommend the AAFP focus resources.
To get us started I have created a top 15 list of priority issues:
- Physician payment (specifically primary care);
- Primary care workforce and graduate medical education reform;
- Delivery system reform and innovation;
- Electronic medical records and meaningful use;
- Health system financing, coverage and insurance reform;
- Medicaid expansion;
- Children’s Health Insurance Program reauthorization;
- Telemedicine, digital health and medical apps;
- ICD-10 implementation;
- National Health Service Corps reauthorization and funding;
- Administrative simplification;
- Network adequacy (Medicare, Medicaid, health insurance marketplaces);
- Social determinants of health and health disparities;
- Health care consolidation and antitrust issues; and
- Professional liability insurance reforms.
In addition to the list of issues, I wanted to expand on three important areas where the AAFP will be focusing significant resources on your behalf. These three items are routinely identified by our members and state chapters as the top advocacy priorities for family physicians. Although the information below is not exhaustive, it is a fair depiction of the top policy issues we have identified for the 114th Congress.
There are four priorities for the AAFP in this area: sustainable growth rate (SGR) formula reform, the Medicare Primary Care Incentive Payment program, improved Medicaid payment policies for primary care, and the establishment of a new payment formula for primary care.
Under current law, the Medicare physician payment rate will be reduced by 20.1 percent on April 1 unless Congress takes action to prevent this cut. It is highly anticipated that Congress will take the necessary steps to prevent this draconian cut, but it is unclear if legislators will attempt to enact long-term payment reforms prior to the 2016 election. The early line is that Congress will enact a 20- to 24-month extension of current payment rates in March and then make a run at permanent repeal of the SGR in November/December 2016.
The Primary Care Incentive Payment (PCIP) program was established by the Patient Protection and Affordable Care Act and provides a 10 percent add-on to eligible Medicare payments for qualifying physicians. The program is set to expire Dec. 31, 2015. This important policy has benefited thousands of family physicians and increased access to primary care for beneficiaries, and we are making its extension a top priority.
Medicaid parity payments ended Dec. 31, 2014. More than a dozen states have made a commitment to continuing the payment policy in 2015 at their own expense. We are pleased to see these states take such action, but we continue to believe that the establishment of an equitable primary care payment rate for the Medicaid program should be part of the federal mandate for states receiving federal matching funds.
Workforce and Graduate Medical Education
The AAFP has placed a priority on increasing the primary care physician workforce by expanding both the type and number of graduate medical education programs for family physicians. During the 114th Congress, we will actively seek to further establish the AAFP as the leading voice on primary care workforce and graduate medical education.
During a Capitol Hill briefing in September, the AAFP unveiled its GME reform policy proposal “Aligning Resources, Increasing Accountability, and Delivering a Primary Care Physician Workforce for America.” The proposal has garnered much attention and, along with the Institute of Medicine’s GME proposal, “Graduate Medical Education That Meets the Nation's Health Needs,” has challenged conventional wisdom on the issue of GME structure and financing. Since the release of our GME proposal, we have conducted numerous meetings with congressional legislators and staff and thought-leaders inside the administration and academia.
The AAFP will continue to advance policies that challenge the hospital-based GME system and place a greater emphasis on ambulatory training opportunities that are appropriately funded. A critical component of these efforts will be the reauthorization of the Teaching Health Center program, which expires in 2015. In addition to reauthorizing the program, the AAFP will be advancing policies that aim to establish a more predictable and robust funding mechanism for the program in contrast to the current funding formula which has proven inadequate to support it.
Electronic Health Records
The next two years will be critical to our national efforts to create and implement an interoperable electronic health records system. As the meaningful use program enters the penalty phase, more than 250,000 physicians can expect reductions in their Medicare payments due to their non-participation in the program. For those who are participating, the program is not proving to be a walk in the park. The program is fraught with problems and the “one-size-fits-all, check box, pass/fail and then get audited” style of MU phase 2 has most physicians anxious, if not angry. We are having ongoing discussions with the Office of the National Coordinator of HIT and the Congress on these issues. Although a solution isn’t yet available, we are hopeful that the MU program will be improved during the next 12 months.
A national, interoperable health records system should not be unobtainable, yet it remains so. Maybe 2015 will be the year that an industry that has benefited from $29 billion in government-backed purchasing power will reverse its epic failures and assist those who are trying to actually use their products for the betterment of patient care.
One of the unique aspects of our governing structure is that every two years we get to start over. Similar to an Etch A Sketch, we simply shake off the old and create a clean canvass for the next two years. As a new Congress begins, I hope each of you will continue to engage with the AAFP in our advocacy efforts. Share your thoughts and help us better meet your needs and expectations. In the meantime, I wish you a healthy and prosperous 2015.
AAFP's Advocacy Efforts Paved Way for New Care Management Code
Get to know these five digits – 99490 -- because they will be important to you and your practice and have the potential to be transformational to our health care system.
These five numbers are the new CPT code for the chronic care management service, which family physicians participating in Medicare will be entitled to bill for each eligible Medicare patient starting Jan. 1. This policy is a significant change in the Medicare physician fee schedule for family physicians and is reflective of years of advocacy work by the AAFP.
Family physicians have long argued that the most valuable services they provide their patients occur outside of the traditional face-to-face office visit. The variation and volume of these services have increased significantly as patients, especially those with multiple chronic conditions, live longer, more active lives, requiring more consistent interactions with their physicians, many of which do not require a face-to-face encounter with the physician. This increase in patient interactions has been facilitated by advances in technology that allow for asynchronous communication and the rapid transmittal of information between physicians and care sites.
Family physicians and their practices have always been defined by continuous and comprehensive care. In recent years, a third “c” was added to the list -- connected. Today, the delivery of continuous, comprehensive, and connected care is what family medicine is all about.
Through the 1990s and early 2000s, care management fees were viewed negatively by payers at all levels -- including the federal government. The concept of paying physicians for services provided outside of the face-to-face encounter was deemed of limited value. The AAFP ferociously disagreed with this line of thinking and aggressively moved to educate public and private payers on the value of care management services and how these services were essential to improving quality and lowering long-term costs.
As the health care system began to adopt advanced primary care delivery models, such as the patient-centered medical home, the value of care management became more apparent to those that previously viewed them with a degree of skepticism. Today, there is near consensus that care management by family physicians and primary care practices is essential to achieving higher quality care for patients. More importantly, there is consensus that these services must be paid.
In 2013, CMS first proposed paying for chronic care management services under the Medicare physician fee schedule. The inclusion of this new service in the fee schedule was largely a result of AAFP advocacy efforts.
CMS, through rulemaking, has established that the Medicare allowance for the chronic care management (CCM) service provided to an eligible patient will be approximately $42 for a calendar month. The payment is subject to Medicare deductible and co-insurance policies. Physicians will be allowed to bill the CCM code for services provided to Medicare patients with multiple chronic conditions that are expected to last more than 12 months, or until the death of the patient, that place the patient at significant risk of death, acute exacerbation/decompensations, or functional decline.
CMS is encouraging physicians to acutely focus on patients who have four or more chronic conditions but has established the eligibility criteria at two or more chronic conditions.
The AAFP has an excellent tool to assist with risk-stratified care management that will benefit you with the CCM code.
To receive the CCM payment, a family physician must collect a signed patient agreement, and the practice must provide at least 20 minutes of physician-directed, clinical staff time per month that aligns with eight performance elements:
- access to care management services;
- continuity of care;
- care management for chronic conditions;
- creation of a patient-centered care plan;
- management of care transitions;
- coordination with home and community-based clinical service providers;
- enhanced communication with patients and care givers; and
- electronic capture and sharing of care plan information via a certified electronic health records system.
The AAFP has created a variety of resources aimed at assisting family physicians and their practices. I urge you to read “Chronic Care Management and Other New CPT Codes.” This article will appear in the January/February 2015 edition of Family Practice Management, but it already is available online.
The AAFP also has created a Frequently Asked Questions document about the CCM benefit, a sample patient agreement/contract, a Medicare chronic care management service log, and patient-centered care plan template. These four resources were created to assist family physicians in securing the CCM payments and are available on the AAFP website.
Finally, please join the AAFP for a free webinar, “Getting Paid for Chronic Care Management Under Medicare in 2015,” on Jan. 27 at 1:30 p.m. Eastern.
This is the final In the Trenches for 2014. Thank you for engaging with the AAFP on our advocacy efforts during the past year. Your views, opinions, and suggestions make us better and allow us to focus our advocacy resources on those items that have the greatest impact on you and your patients. The next edition will publish on Tuesday, Jan. 6. I wish you and your families a wonderful holiday season and a prosperous new year.
Analyze This: Graham Center's Work Shows Value of Primary Care
The power of informed debate is something that is often overlooked and undervalued in our current political environment -- especially in health care where emotion can often override sound policy. The ability to evaluate policies, data, and trends is essential to the improvement of our health care system.
The need for such analysis is what led physician researchers such as Kerr L. White, M.D., to establish a field, as he described it, devoted to the “study of the relative benefits, risks, and costs of health interventions for individuals and populations.” Although the field of health services research has existed in some form for hundreds of years, its formal roots in the United States are largely tied to the establishment of the National Center for Health Services in 1968. Today, it is known as the Agency for Health Care Research and Quality (AHRQ) and remains at the forefront of the federal government’s efforts to "produce evidence to make health care safer, higher quality, more accessible, equitable, and affordable."
The AAFP also recognized the importance of producing evidence that demonstrated the value of family medicine and primary care, and, its impact on the health of individuals and our health care system. In 1997, the AAFP Board of Directors approved the development of a Center for Policy Studies in Family Practice and Primary Care. The center, which is located in Washington, D.C., is charged with producing research and analysis that informs deliberations of the AAFP and its public policy work. It also provides the perspective of family medicine to policy debates in Washington and around the nation.
In 1999, the center began operations with a research agenda focused on "policy questions related to family physician services and the general domain of primary care." In 2000, the center was renamed, in honor of former AAFP Executive Vice President Robert Graham, M.D. This year the Robert Graham Center for Policy Studies in Family Medicine and Primary Care is celebrating its 15th anniversary, a milestone worth noting. During the past 15 years, the Graham Center has grown into a nationally recognized research center that is at the forefront of health services and economic research. It is a resource unique to family medicine, and we should celebrate its contributions to the advancement of family medicine and the betterment of health care policy.
Today, the Graham Center focuses its research agenda around four themes: the value of primary care; health access and equity; delivery and scope of the medical home; and healthcare quality and safety. Although the center has a broad and impactful research agenda, its contributions to physician workforce research is the cornerstone of its success. The center’s research on physician workforce has directly influenced policies at the federal and state levels and is the foundation for programs such as teaching health centers and rural training tracks. The center has published a state-by-state analysis of workforce projections that influences decisions made by state legislatures and governors and empowers family medicine advocates in all 50 states.
In recent years, the center has expanded its research portfolio to focus on issues that directly and indirectly impact the economic viability of family medicine practices. These research projects range from payment policies to analysis of new and emerging delivery models such as the patient-centered medical home and direct primary care. In the past year, the Center published an analysis on Blended Payment Models and Associated Care Management Fees. This document already is influencing public and private payment policies and is a tremendous resource that I encourage you to familiarize yourself with.
Although the research work of the Graham Center remains its highest priority, it is important to note that it also has emerged as one of the top incubators of the next generation of family medicine and primary care researchers through its visiting scholars and fellows programs. Since the inception of these two programs, more than 120 family medicine researchers have participated. This network of scholars includes individuals who now serve as leaders in academic and government institutions across the nation and around the world. Training future research leaders is an investment that will pay dividends for family medicine for generations to come.
The establishment of the Robert Graham Center was a forward thinking decision by the AAFP and indicative of the manner in which we continue to deploy resources in a manner that benefits patients, our members, the discipline, and our health care system.
Critical Issues at Stake for Primary Care in Lame Duck Session
I start this week’s posting with an urgent request. If you accept Medicaid in your practice and you do not want to see your payments for services provided to Medicaid patients slashed by, on average, 40 percent, I encourage you to take a few minutes today to send a letter to your representative and senators urging them to extend the Medicaid Primary Care Incentive Payment Program.
Unless Congress acts, Medicaid payment rates for primary care services will return to 2012 levels levels on Jan. 1, 2015. Please visit Speak Out and send a letter to your elected officials today. After you send your letters, please encourage your colleagues, friends, and neighbors to do the same.
On Sept. 29, the AAFP sent a letter to House and Senate leadership urging action on this issue. We continue to actively lobby legislators to extend this provision, but we need your help!
With the mid-term elections in the rearview mirror, the 113th Congress has returned to Washington to complete its work in what could be an eventful lame duck session. Although the lame duck session will be relatively short in duration, the days will be jammed with lingering legislative items needing attention. Besides the Medicaid payment policy outlined above, there are several other items on the AAFP’s year-end to-do list for Congress.
One of the most important things Congress must do is fund operations of the federal government. Prior to the elections, Congress approved a continuing resolution funding the government through Dec. 11. Now Congress must develop and pass funding to sustain government operations through the end of the fiscal year, which ends on Sept. 30, 2015. This process is complicated by the need for additional funding to support domestic and foreign efforts to combat the Ebola virus and evolving foreign policy issues.
The AAFP has several priorities in play that will be directly impacted by the appropriations spending bill. At the top of that list is financing for the National Health Service Corps and other primary care programs included in the Health Resources and Services Administration budget. Also, there are some concerns that funding for primary care research at the Agency for Healthcare Research and Quality could be in jeopardy. The AAFP is actively promoting the continuation and responsible funding for each of these programs. On Oct. 28 we joined more than 100 organizations in sending a letter to House and Senate leadership urging them to avoid the “primary care cliff” by preserving funding for these important programs.
For physicians, fall is once again the time of year when we wonder if payments will be slashed by a draconian funding formula that has haunted physicians for more than a decade -- the sustainable growth rate (SGR). In March, Congress enacted a short-term extension of Medicare physician payments, preventing scheduled cuts of more than 20 percent. This short-term reprieve expires on March 31, 2015. At that time, Medicare payments will be slashed by 21.2 percent unless Congress intervenes. I laid out a compelling argument for why Congress should act in the lame duck in a recent column for The Morning Consult.
The AAFP is aggressively lobbying Congress to act in the lame duck session to enact SGR repeal legislation, and this also is an issue that we could use your help with. Your elected officials need to hear directly from you regarding the negative impact the failed SGR formula is having on your practice and the patients you care for. I encourage you to engage with us in this advocacy effort by visiting our Speak Out page.
The Administration recently requested emergency funding for the domestic and foreign Ebola response. Although the amount of spending is still under discussion, it will be significant. The AAFP supports the increased funding which would improve our public health system and expand our capabilities to identify, isolate, and treat patients with infectious diseases such as Ebola. As an organization representing physicians who find themselves at the leading edge of public health, we view this funding as essential.
The next item on the AAFP’s to-do list is the confirmation of Vivek Murthy, M.D., as Surgeon General. The AAFP recently joined with other physician organizations to articulate why the Senate should act immediately to confirm Dr. Murthy. The health of our population is not a partisan issue, and our public health service is deserving of effective leadership, which Dr. Murthy would provide. The AAFP strongly supports his nomination and we are urging the Senate to act prior to adjournment to confirm Dr. Murthy.
On Nov. 1, CMS released the 2015 Medicare Physician Fee Schedule. This regulation establishes physician payment rates for the coming year and outlines several new policy changes within the Medicare program. The final regulation is painfully long, so the Academy has developed a manageable summary for family physicians. There also is a great AAFP News article that summarizes the major provisions of the final rule.
Less Than One Year to ICD-10; Will you be ready?
There are few topics in health policy that I am hesitant to discuss, but today’s topic is one of them. Lucky for me, there is probably an ICD-10 code for “scared to discuss ICD-10 codes, initial encounter.”
The International Classification of Diseases (ICD) coding system has been a part of our national health care system since 1979. Although the implementation of ICD-9 wasn’t without resistance, it was mild compared to the collective negative reaction received to ICD-10. ICD-10 is one of those issues that symbolize what many physicians consider to be the “over-regulation” of the U.S. health care system.
This collection of codes is fascinating to those that study and write about our health care system, but they are costly and of questionable value to those that actually provide patient care. In a world of “paying for value,” ICD-10 seems to miss the mark in the minds of most physicians.
So, how did we get here? The 43rd World Health Assembly endorsed the ICD 10th Revision in 1990, and limited implementation by some WHO countries began in 1994. In response to the WHO, the U.S. National Center for Health Statistics developed the ICD-10-Clinical Modification (ICD-10-CM) to ensure greater accuracy and clinical utility in 1993 and made the code set available in 1995. In 1996, the Health Insurance Portability and Accountability Act (HIPAA) was enacted into law. Included in that law were provisions that allowed for a standard code set to be established under the Administrative Simplification provisions of the law. In 2003, the National Committee for Vital and Health Statistics recommended to the Secretary of HHS that the United States move forward with adoption and implementation of ICD-10-CM and ICD-10-PCS (procedure coding system) under HIPAA standards.
The reaction by physicians and insurers was swift and negative. The sheer costs of implementation would be expensive and, in the minds of many, a complete disaster (not much changed from 2003 to 2014). Remember that, in 2003, the use of electronic health records (EHRs) was nascent, which made the transition to ICD-10 seem, well, impossible. The political pressure to prevent the transition to ICD-10 began to fade following the HITECH Act, which facilitated a broader adoption of EHRs in our health care system. As EHRs became more prevalent, the pressure to transition to ICD-10 intensified. On Jan. 5, 2009, the waiting finally ended when HHS announced that all HIPAA covered entities would be required to comply with ICD-10 on Oct. 1, 2014.
Although an implementation date was set, the opposition to ICD-10 did not subside. In fact, many physicians became even more concerned that the cost of implementing EHRs and ICD-10 would overwhelm their available resources.
The AAFP also was concerned with the impact such a transition would place on family physicians, but we were equally concerned about the ability of our nation’s health care system to shift to a new system. Our health care system isn’t exactly adept at large scale reforms, and ICD-10 is reform on an unprecedented scale.
On Feb. 25, 2014, the AAFP wrote a letter to then HHS Secretary Kathleen Sebelius outlining these concerns and calling for “end-to-end” testing of ICD-10 with an emphasis on solo and small group practices. As more time passed, the AAFP’s concerns grew more profound, and we called on Congress to delay implementation for one year to provide family physicians additional time to successfully make the transition. In April 2014, Congress agreed to delay implementation one additional year as part of the Protecting Access to Medicare Act of 2014, a larger physician payment bill.
Today, we have less than a year until the new, most dreaded, date of Oct. 1, 2015, arrives. Although the AAFP’s concerns remain, we realize there will be no more delays, and family physicians will be required to comply with ICD-10. Recognizing that our members need resources and assistance, the AAFP developed a number of valuable tools aimed at assisting you and your practice in the transition to ICD-10:
- Frequently Asked Questions on ICD-10
- ICD-10 Timeline, which is designed to assist you with budgeting, planning, communicating, training, implementing, and monitoring your transition to ICD-10.
- ICD-10 Cost Calculator to provide you a cost estimate on implementing ICD-10 in your practice.
- ICD-10 Flashcards, which provide a crosswalk between ICD-9 and ICD-10 codes for the 823 most common primary care diagnoses. They are color-coded for quick recognition and contain coding tips to assist in accuracy in coding. Purchasing these flashcards will be the best $79 you spend this year.
- ICD-10 Educational Series. This set of tools consists of 11 family medicine-specific modules developed by coding experts to assist you and your practice. The modules focus on the top-50 diagnosis codes in primary care. Each module is 10 to 20 minutes and can be viewed individually or with your practice team on your schedule.
In addition to these resources, Family Practice Management has compiled a collection of journal articles regarding ICD-10.
We continue to advocate for greater resources and testing from CMS. To its credit, CMS is listening and working with the AAFP to increase the availability of such resources. CMS has published “The Road to 10” toolkit, which is designed to assist small practices with the transition. In addition, they have announced three additional weeks of testing:
- Nov. 17-21, 2014,
- March 2-6, 2015, and
- June 1-5, 2015.
For more information on how you can participate, visit the CMS ICD-10 Provider Resource page.
It is incumbent on the AAFP to tell you that ICD-10 is going to happen, and we urge you to prepare your practice. We have numerous resources that can assist you and your staff, and we urge you to use them. In the end, we all can only hope that there is an ICD-10 code for “trauma caused by regulation, reoccurring event."
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