The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Sept. 11 in response to the CY 2024 Physician Fee Schedule and Quality Payment Program proposed rule.
The CMS proposed the conversion factor of $32.7476, which is a 3.6% reduction from the 2023 conversion factor. In the comments the association noted that, “payment reductions of this magnitude would pose a major problem at any time, but to impose these cuts at a time when teaching physicians and other health care professionals are still recovering from the financial impact of the COVID-19 pandemic, experiencing historic workforce shortages, and record-setting inflation and rising practice costs, will be extremely harmful.”
The comments urged the CMS to make permanent the telehealth COVID-19 flexibilities, as they increase patient access to care and allow for a more efficient use of in-person resources. The letter encouraged the agency to finalize its proposal to pay the same amount for in-person services when a practitioner is providing telehealth to the patient at home, beginning Jan. 1, 2024, as it improves access to care by recognizing and reimbursing for the infrastructure and staffing costs for telehealth care, beyond the clinicians’ time and clinical expertise. The comments also urged the CMS to make permanent virtual supervision of residents providing telehealth and to extend this policy to include in-person services, when clinically appropriate.
The letter supported the CMS’ effort to increase access to behavioral health care services by increasing payment for general behavioral health services and psychotherapy codes and allowing marriage and family therapists and mental health counselors to independently bill Medicare services. Additionally, comments encouraged the agency to promote the use of interprofessional consults for behavioral health by eliminating barriers and to make changes to increase access to behavioral integration services.
In response to the Quality Payment Program proposals, the association’s letter “encourages CMS to work with key stakeholders to identify longer term policy solutions in the future that would improve quality, attain health equity for all beneficiaries, improve patient outcomes, and reduce burden.” Comments also responded to numerous proposals to modify policies for the Medicare Shared Savings Program.