Society Comments on CMS Patient Relationship Categories and Codes Feedback Request
As a result of the passage of Medicare Access and CHIP Reauthorization Act (MACRA), the Centers for Medicare & Medicaid Services (CMS) is now required to establish and use classification code sets: care episode and patient condition groups and codes, and patient relationship categories and codes. CMS recently issued request for feedback to addresses the patient relationship categories and codes required. The development of patient relationship categories and codes is new work for CMS. The ability to attribute patients to clinicians (in whole or in part), based on clinician reporting of the different relationships that they have with their patients is something that currently does not exist in current coding procedures.
The Society submitted formal comments on this request noting that, “Physicians who practice in post-acute/long-term care (PALTC) medicine take care of patients who are unique, vulnerable, often frail with multiple chronic conditions and functionally impaired. The resources necessary to take care of this population are vastly different from the resources to take care of the ambulatory, community-dwelling elderly population in the office setting.” The Society also stated that “implementing patient relationship codes that reflect the appropriate relationship between the physician and the patient will allow CMS to compare physicians that take care of similar populations. Physicians who take care of patients in nursing facilities typically serve two distinct populations –short-stay, post-acute, “skilled” patients and long-stay, chronic, custodial residents.”
The Society helped to further define the two populations served noting that “for short-stay skilled populations, physicians typically serve in a more “specialist-type” capacity, similar to that of a hospitalist in the acute care hospital, and only have a short-term relationship with the patient that is limited to the patient’s time in the facility, before the responsibility for treatment is turned back over to the care of the primary care practitioner (PCP) upon discharge from the facility. This patient population is currently designated in billing by their place of service (POS) 31 – skilled nursing facility (SNF). For the long-term, chronic patients who reside at the nursing home and are receiving custodial care, physicians have a more long-term relationship and serve as their PCP throughout their stay and possibly end-of life. This population is currently designated in billing by their by POS 32 –nursing facility (NF).”
The Society also took the opportunity to address concerns about accurate cost attribution under value-based payment models. “In order for these patient relationship codes to be successful, they must accurately attribute costs, in conjunction with episode groups, to physicians who actually have control over the costs accrued by the patient. This is especially true for PALTC based physicians, who are at risk for unfairly having costs attributed for an episode of care that originates in the hospital, goes through SNF (POS 31) and ends in the community. In that instance CMS needs to ensure that the costs of care be attributed to the physician who has the most control over that care—and most of the costs of such a treatment may be accrued in the hospital, not the nursing home.” The Society pushed for flexibility as CMS goes through this process because “the exact attribution and cost allocation rules are likely to vary according to the type of service or condition involved. CMS, therefore, must provide more information regarding how the patient relationship categories and episode groups will attribute care to physicians, and must continue to work with stakeholders to ensure the care attribution methodology accurately attributes costs to the physicians who actually have the most control over the costs of care.”
To read the entire comment letter click here.