ACP is particularly pleased that CMS is proposing that all physicians with the specialty designations of family medicine, general internal medicine, or pediatric medicineas well as all subspecialists within those three specialty designations, as recognized by the American Board of Medical Specialtiesbe eligible for increased payment. This is encouraging because while primary care physicians do provide the bulk of services accounted for by the specified evaluation and management (E&M) and vaccine administration codes, there are a significant number of internal medicine and pediatric subspecialists that also provide these servicesand they should be included as well.
In addition, ACP is encouraged that CMS is proposing to include non-Medicare covered primary care services in the list of specified codes because these services do represent a core component of services commonly delivered in the Medicaid program. These services include comprehensive preventive medicine, counseling for risk factor reduction and behavior change, and non face-to-face interactions.
Finally, it is important to note that for 2013-2014 states will receive 100 percent payment by CMS for their expenditures equal to the difference between the Medicaid state plan rate for primary care services and the Medicare rate. Because CMS will be paying for the increase with federal dollars as authorized by the ACA, the increased Medicaid payments for primary care will not result in offsetting cuts in payments to other (non-eligible) physicians and specialties. After December 31, 2014, states are permitted to continue funding Medicaid primary care reimbursement rates at or above Medicare levelsbut without additional federal funds, unless the program is reauthorized through new legislation. ACP will be urging Congress to extend the program.
ACP will be submitting detailed comments to CMS on this proposed rule in the coming weeks, with the intent of providing meaningful feedback on ways improve the rule prior to it being finalized.
Provided by American College of Physicians
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