Federal Policy Updates

For state specific policy head to State Policy Updates


CMS Finalizes Medicaid Primary Care Access Standards sought by Better Health — NOW

In a win for tens of millions of children, adults and communities that rely on Medicaid and CHIP, CMS has finalized new primary care access standards  long sought by PCC and our Better Health – NOW Campaign.

Under new federal transparency requirements, state Medicaid programs and plans must publish comparisons of primary care payment against payment rates from Medicare and other payers.  CMS also finalized proposals to strengthen beneficiaries’ voice in state Medicaid program governance and to address health related social needs through In-Lieu-of-Services payments. 

“The transparency requirements will spotlight the glaring disparity between Medicaid primary care payment rates and other health plans – a disparity that hits rural and underserved communities the hardest,” said Larry McNeely, PCC's Director of Public Policy . Independent analysis from the Urban Institute has estimated that primary care rates are just 67% of Medicare’s.

“The onus then falls on federal and state policymakers to leverage the new transparency to actually close those gaps, and on primary care stakeholders to make them do it,” added McNeely.

CMS’ announcement follows BHN’s two years of persistent engagement, dating from PCC's Medicaid RFI response in April 2022, through 2023 comments on the proposed rules, to the January 2024 release of Better Health – NOW’s Medicaid Priorities.

Better Health – NOW, a Campaign of the Primary Care Collaborative, has identified reducing economic and social barriers through stronger Medicaid and CHIP primary care as a core policy goal.  To learn more about the Campaign, click here

Primary Care Champions: Dr. Meena Seshamani and Liz Fowler

This month, the Primary Care Collaborative is thrilled to honor two leaders from the Center for Medicare and Medicaid Services (CMS) as its Primary Care Champions:

Dr. Meena Seshamani, Deputy Administrator and Director of the Center for Medicare; and Liz Fowler, Deputy Administrator and the Director of the CMS Innovation Center.

As leaders at CMS, Meena and Liz and their teams at the Center for Medicare and CMS Innovation Center have collaborated to champion thoughtful and innovative approaches to improve seniors’ access to high-quality, whole-person primary care.

“It’s so important that we have primary care doctors that are supported and able to care for people the way they want to be cared for,” said Meena in a short interview with PCC. “It’s been very important to me… to support primary care because it really serves as a cornerstone and foundation for how we want to innovate, to provide whole-person care to everybody in our country.”

Their commitment is driven by their recognition of the essential role that primary care plays in care management and prevention.

“We know that people who have access to high-quality primary care are more likely to receive preventive health services and screenings and to experience improved health outcomes related to mortality, disease progression, and chronic condition management,” said Liz in the same interview.

Under Meena and Liz’s leadership, the Center for Medicare and CMS Innovation center have worked together on myriad efforts to strengthen payment policies for primary care both in new models and in the underlying Medicare program — most recently with the launch of the ACO PC Flex hybrid payment model under the Medicare Shared Savings Program (MSSP).

ACO PC Flex’s launch came less than a year after PCC and 30 other health care organizations urged CMS leaders to implement a hybrid program under MSSP.

Meena cited the ongoing success of existing primary-care centered ACOs as a major motivator for developing the program, noting that primary-care led ACOs share in nearly double the savings of other ACOs.

The new payment model is designed to encourage primary care practices to participate and lead in ACOs.

“The models flexible payment design is intended to empower participating ACOs and their primary care providers to use more innovative team-based, patient-centered and proactive approaches to delivering care,” said Liz.

The PCC is grateful to Meena, Liz and the teams at the Center for Medicare and CMS Innovation Center for their ongoing commitment to advancing the promise of primary care.

Click here to learn more about the ACO PC Flex program.

Click here to watch PCC’s webinar exploring the program with CMS Innovation Director Liz Fowler.

Better Health NOW:  Primary Care Must Be At Center of Payment Reform Bill 

On April 24th, the Primary Care Collaborative and its Better Health – NOW Campaign urged the U.S. Senate Finance Committee to put primary care at the center of planned Medicare payment legislation. 

“To address the rising tide of chronic disease discussed…,policymakers must fix the underlying flaws in Medicare Part B’s payment policies,” according to a  Statement for the Record submitted for the April 11th hearing, Bolstering Chronic Care Through Medicare Payment

The Campaign’s statement called for reorienting Medicare to support primary and preventive care: 

  • Require Medicare and other federal programs to report primary care expenditures as a percentage of overall health care dollars 

  • Establish a well-constructed hybrid payment option, broadly available to Medicare primary care 

  • Make Medicare more affordable for beneficiaries, removing cost-sharing for primary care hybrid payments, chronic care management and behavioral health integration services 

  • Accelerate Primary Care-Behavioral Health Integration in Medicare, through bipartisan legislation like the COMPLETE Care Act  

Noting that the success of any Medicare payment reform depends on alignment with other payers, Better Health – NOW also encouraged the Finance Committee to advance targeted policy steps this year that support constructive state Medicaid and private market primary care innovations - including community health center funding, youth mental health improvements and improved coverage for primary care in high-deductible health plans. 

April Senate Finance Committee Hearing Features Primary Care

Primary care played a starring role in a bipartisan April 11th Senate Finance Committee hearing, Bolstering Chronic Care through Medicare Physician Payment, led by Chairman Ron Wyden (D-OR) and Ranking Member MIke Crapo (R-ID).

With PCC members and team in attendance, Chairman Wyden responded directly to a recommendation from hearing witness Amol Navathe, MD, PhD that Congress create a path to scaling hybrid primary care payment, saying, “I like that idea very much.” Dr. Navathe is a physician and Professor at the Unversity of Pennsylvania.

Over the past year, PCC and its Better Health – NOW Campaign championed a hybrid payment option with CMS – now reflected in the new ACO PC Flex Model available next year to up 130 Medicare ACOs.  But Congress has a crucial role to play as well.

Earlier this spring, Better Health – NOW  argued  that “primary care is a primary solution to address chronic physical and mental health conditions and the increasingly unaffordable costs they generate,” in submitted testimony to the Senate Budget Committee. The Campaign will be submitting additional recommendations to the Senate Finance Committee later this week.

“The first place to start is to invest more in primary care.” argued Navathe.

PCC Applauds CMS/CMS Innovation Center for Taking Steps to Strengthen Primary Care in Medicare

Washington, D.C. (March 19, 2024) – The Primary Care Collaborative (PCC) applauds the Centers for Medicare and Medicaid Services (CMS) and the CMS Innovation Center for taking substantive steps to strengthen primary care to deliver better outcomes by announcing a hybrid payment model under the Medicare Shared Savings Program (MSSP).

The announcement comes less than a year after PCC’s Better Health – NOW mobilized more than two dozen stakeholder organizations in support of CMS and the Innovation Center implementing hybrid payment models (mix of prospective and fee for service) to encourage primary care participation in MSSP and develop primary care led accountable care organizations. NASEM’s 2021 report underscored the evidence related to hybrid payment.

“Primary care is the foundation of an equitable, effective health care system,” said Ann Greiner, President and CEO of the PCC. “Today, CMS and the CMS Innovation Center demonstrated they understand the urgent need to reinforce that foundation.

“We’re also encouraged to see that this model centers equity by promoting participation by rural health clinics and federally qualified health centers, puts guard rails in place to ensure payments reach primary care practices and benefits beneficiaries by giving clinicians a prospective payment that allows them to deliver more flexible, comprehensive care. We’re eager to learn more about this model and its potential to lower costs and improve beneficiary outcomes.”

Dr. Liz Fowler, Director of CMS Innovation Center, will provide additional details about the new model in a presentation and Q&A with PCC President and CEO Ann Greiner during a PCC webinar earlier today. The webinar also featured thoughts and reactions from leaders at the National Association of Community Health Centers, the American Academy of Family Physicians, the National Association of Accountable Care Organizations and the National Partnership for Women and Families.

Registration for the webinar is open here.

 

About the Primary Care Collaborative

Founded in 2007, PCC is a multistakeholder organization dedicated to advancing an effective and efficient health system built on a strong foundation of primary care. Representing a broad coalition that includes patient and consumer advocacy groups, health care clinics, professional societies, payers, leading corporations and other health care stakeholders, the PCC’s mission is to unify and engage diverse stakeholders in promoting policies and sharing best practices that support the growth of high-performing primary care to achieve the “Quintuple Aim”: better care, better health, lower costs, greater joy for clinicians and staff, and greater health equity.

PCC Sends Recommendations on Strengthening Primary Care for Rural & Underserved Communities to House Ways & Means Leaders

With a December 14 letter, the Primary Care Collaborative (PCC) is applauding House Ways and Means Committee leaders for their efforts to date to develop solutions for healthcare access in rural and underserved locales and offering its own recommendations to strengthen primary care for all communities.

Rep. Jason Smith (R-MO), Chairman of the House Committee on Ways and Means, has identified rural health as a priority for the Committee. Earlier this Fall, the Committee reached out to healthcare stakeholders with a request for information (RFI) on bold solutions to improve healthcare access issues for those in rural and underserved communities.

PCC’s recommendations to Chairman Smith and Ranking Member, Rep. Richard Neal (D-MA) include the following:

  • Invest in primary care by supporting CMS’ work to develop a hybrid payment option in the Medicare Shared Savings Program (MSSP), and pay adequately for inherently complex care (G2211 code)
  • Integrate mental health and addiction services by expanding Primary Care-Behavioral Health Integration (BHI), improving Medicare’s Health Professional Shortage Area Bonus program, removing barriers to BHI in Federally Qualified Health Centers and Rural Health Clinics, supporting telemental health and tele-prescribing services
  • Address misaligned Medicare policies that impact beneficiaries who are dually eligible for Medicare and Medicaid (duals) by establishing continuity of coverage protection for duals, expanding access to the Program of All-Inclusive Care for the Elderly (PACE), address the serious coverage and reimbursement barriers (“lesser-of payment policies”) for duals

While PCC applauds the Committee’s first steps to explore access for rural and underserved communities, we encourage them to take the bold action necessary to enact these improvements in the New Year.

U.S. Representatives Introduce the COMPLETE Care Act to Support Behavioral Health Integration

On July 26th, with the full support of PCC and its Better Health – NOW Campaign, U.S. Representatives Michelle Steel (R-CA), Dan Kildee (D-MI), Lizzie Fletcher (D-TX), Gus Bilirakis (R-FL), August Pfluger (R-TX), and Susie Lee (D-NV) introduced H.R. 5819 the COMPLETE Care Act of 2023. A companion bill to the Senate’s S. 1378, this House legislation would improve the behavioral health care available to Medicare beneficiaries in primary care settings through:  

  • enhanced Medicare payment rates for collaborative care and general behavioral health integration services,  

  • support for quality measure reporting for behavioral health integration, and  

  • investment in technical assistance to broaden adoption of integrated care. 

Read PCC’s Letter of Support.

Read the bill sponsors’ press release

Better Health – NOW Praises Draft Medicare Payment Rule but Calls for Bolder Action

In comments submitted to the Centers for Medicare and Medicaid Services (CMS) on September 11th, the Primary Care Collaborative’s Better Health – NOW Campaign backed several provisions of Medicare’s proposed 2024 Part B Physician Fee Schedule rule, while urging still bolder action to address the unfolding crisis in primary care workforce and access.

The comments reflect broad consensus across PCC’s multistakeholder Better Health – NOW Campaign. The letter calls on CMS to:

  • Invest in whole-person primary care by implementing payment for inherently complex care (the G2211 code) as well as improved reimbursement for behavioral health services and vaccine administration.
  • Bolster primary care in ACOs by quickly implementing a PCC/NAACOS hybrid proposal which would offer upfront, population-based payment options to Medicare Shared Savings Program (MSSP) primary care practices.
  • Help primary care teams support whole-person health, by finalizing reimbursement for lifestyle change and community health integration as well as improvements to behavioral health integration services.

PCC’s Better Health – NOW Campaign applauds CMS for their efforts to support primary care teams in addressing behavioral health and complex care needs. However, we encourage CMS to respond swiftly to the primary care crisis by increasing investment and offering pathways for practices to transition from fee for service to population-based, prospective payment models.
 

Download and read the full comment letter here.

Pay for What Patients Want: Primary Care for the Whole Person 

 

If you or someone you love depends on Medicare, you know managing that person’s health isn’t easy. Even on a good day, you may find yourself navigating multiple chronic health needs while simultaneously addressing the mental, behavioral and cognitive health conditions.  

If that’s your situation, continuous, whole person primary care - where a trusted clinician actually listens to you, gets to know you and ensures your goals and needs don’t get lost in our complicated healthcare system – can be a game changer.  If there was any doubt of that, research over the years continues to show that improved continuity in primary care reduces mortality while constraining health care expenditures and hospitalizations.  

Unfortunately, the way Medicare pays for health care tends to reward tests and procedures…but starves this kind of personalized primary care of the support it needs.   (That’s one reason why we see so many ads for the hospital’s latest surgical wing on billboards, but finding a timely primary care appointment keeps getting harder.) 

In two Presidential administrations – Republican and Democratic – Medicare officials have proposed that Medicare actually cover and pay for this kind of continuous, inherently complex care. (Medicare even gave the service a billing code: G2211.) After one Congressionally-mandated delay, that long-needed policy is now proposed to go into effect on January 1st, 2024.  

But some on Capitol Hill, at the urging of the same specialty lobbies who win out under today’s payment system, may be tempted to roll back Medicare’s proposal yet again. 

When much of health care quickly shuffles people through the doors, covering and paying for complex care could drive more resources to your trusted source for primary care. That support, in turn, can help your primary care practice do a better job of delivering all that goes into high-quality, whole person care…helping them dedicate the time needed to fully understand your health needs and build the primary care teams needed to address those needs. 

Paying for continuous, complex care over time is important but not a panacea. PCC’s Better Health – NOW Campaign has called for bolder and broader changes to how and how much we pay for primary care. But investing more now in complex care for people on Medicare is a critical down payment. 

At a time when the U.S. health system is weathering a primary care workforce crisis, another delay in in the G2211 policy and the complex care it supports would be an unacceptable step backwards.  

In our comments on this year’s annual Part B Medicare payment rule, PCC expects to praise Medicare officials for standing strong against political pressure.  Now Members of Congress have to follow their example.  

__________ 

 

 

Statement of Primary Care Collaborative President and CEO and leader of the Better Health – Now Campaign Ann Greiner on the Medicare Part B Notice of Proposed Rulemaking

 

“Twenty-seven diverse organizations have urged CMS to leverage the Medicare Shared Savings Program (MSSP) to transform how and how much the United States invests in primary care. Yesterday’s Notice of Proposed Rulemaking (NPRM) acknowledged the clear value of this hybrid payment approach to the health of people with Medicare. Even as it continues to engage stakeholders, CMS should waste no time in turning this acknowledgment into bold, broad-scale change.

“Medicare Part B’s fee schedule sets the pattern for alternative payment models, state Medicaid programs and private payers.  It’s encouraging that CMS has included proposals to better support complex care management, caregivers, behavioral health, diabetes prevention and community health worker/peer supporter programs. For a senior or disabled person on Medicare, especially those facing inequities, these services can be key to whole-person care, provided that care is built on a strong primary care foundation.

“Primary care is in crisis, and there is no time to waste. CMS should implement hybrid payment models within MSSP that offer flexibility needed to ensure adequate investment in primary care. PCC looks forward to a more detailed examination of the rule with our members - in light of the widening crisis in primary care workforce and access and the proposed rule’s overall impact on primary care payment.”

Ann Greiner, MCP
President & CEO of the Primary Care Collaborative
Leader of the Better Health – Now Campaign

 


 

For more information on the impact of the proposed rule on overall Medicare Part B payment, consult this CMS fact sheet which describes a 3.34% reduction in the Medicare conversion factor applied to fee schedule services.

For more information on the crisis in primary care workforce and access, see The Health of US Primary Care: A Baseline Scorecard Tracking Support for High-Quality Primary Care from the Milbank Memorial Fund and the Physician’s Foundation.

The above statement references a section of the NPRM, which states on page 672:

CMS has also continued to receive significant input from interested parties regarding opportunities to increase participation in ACO initiatives. One such option would be to identify ways that the Shared Savings Program can support ACOs’ efforts to strengthen primary care, such as by providing prospective payments for primary care that would reduce reliance on fee for-service payments and support innovations in care delivery that better meet beneficiary needs and increase access to primary care in underserved communities. Empirical data support the notion that primary care serves as the foundation of high-performing ACOs.

 

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