AMDA to CMS: Keep Proposed Increases to Nursing Home Codes/Stabilize Medicare Payment System

The Society submitted its comments on the CY 2023 proposed physician fee schedule that the Centers for Medicare & Medicaid Services (CMS) issued in early July. In the rule, CMS proposed to significantly increase values (reimbursement) for nursing home family of codes but the Agency stated it sought comments on the proposal given that they had some concerns with these increases. The Society pointed out that the process to arrive at these values was sound and these increases are simply keeping up with the work done in this setting. The Society also asked its members to submit comments with more than 50 individuals as well as AMDA state chapters submitting comments. Likewise, the American Medical Association convened RUC (the panel that recommends the values to CMS) sent a letter urging CMS to finalize these values.

While the nursing home codes themselves saw an increase, CMS did propose an overall cut to the Medicare conversion factor (essentially proposing a cut to all physician Medicare services). The Society, along many specialty societies, urged CMS to not finalize these cuts and work with Congress to establish a long-term stable Medicare payment system. In the short term, the Society argued for the suspension of what is known as the PAYGO requirement and providing relief from some of the Medicare penalties in the pay-for-reporting programs.

In addition to payment issues, the Society urged CMS to further study and address the clinician shortage in PALTC. The Society noted that it has heard from clinicians around the country who are having trouble getting physicians and other clinicians to see patients/residents in this setting. While the workforce crisis among the direct-care staff has been well documented and the Administration has outlined steps to address it, the physician shortage issue has not received as much attention and has not been documented. The Society noted that to address quality of care and workforce challenges in the PALTC setting, the Agency should look at the complete picture of all of those providing care to these patients and residents.

CMS received more than 23 thousand comments on the proposed rule and the Agency is expected to issue the final rule sometime in November.