AMDA Comments on Senate Finance Chronic Care Document

The Senate Finance Committee Chronic Care Working Group recently released their options paper outlining policies being considered as a part of the committee’s effort to improve how Medicare treats beneficiaries with multiple, complex chronic illnesses.

AMDA’s comments to the committee included supporting “proposals that provide additional chronic care management services” to the post-acute and long-term care (PALTC) population. AMDA supported the establishment of additional high-severity Chronic Care Management (CCM) code to reimburse clinicians for coordinating care for beneficiaries living with multiple chronic conditions. These include individuals who reside and/or transition across the PALTC continuum including skilled nursing facilities (SNFs) and nursing facilities (NFs).

AMDA also supported provisions to expand the use of telehealth in non-rural, non-underserved areas, changes to attribution methodology under the current Accountable Care Organization (ACO) models, and use of health information technology (HIT) to improve communication and information sharing to improve the quality of care for chronic care patients in care transitions.

AMDA highlighted the lack of adequate quality measures in current value-based programs that target the PALTC population. In its comments AMDA stated that “improvement in health care delivery for individuals with chronic disease, including older adults, is facilitated in part by the development of quality measures that specifically target the unique needs of these individuals. However, we do not have sufficient measures to assess the quality of care received by this vulnerable population in the PALTC sector. CMS should include the development of measures that focus on health outcomes for individuals with chronic disease in its quality measures plan. Unfortunately many of the current quality reporting programs, such as the Physician Quality Reporting System (PQRS), were designed for the ambulatory setting and although reportable in the SNF/NF, do not reflect best practices or unique patient needs and goals of this population. We urge this committee to shift focus away from a “check-the-box” approach to a more person-centered comprehensive approach to quality of care and quality of life measurement that includes realistic parameters based on individual goals of care, prognosis and comorbidities.”

The Senate working group will use submitted comments to aid the committee in producing a bipartisan legislative product that can be introduced and advanced through the Finance Committee.

Click here to read AMDA’s comment letter.