Capitol Hill Report: AAN comments on Medicare Fee Schedule
September 9, 2024
Issue in focus
Each year, the Centers for Medicare and Medicaid Services (CMS) proposes updates to payment policies under Medicare Fee for Service and allows stakeholders, including the AAN, an opportunity to comment on the proposals contained in the Medicare Physician Fee Schedule (MPFS) proposed rule. On September 3, the AAN submitted comments to CMS to provide the agency with insight on how these proposed changes impact neurology, show support for positive changes, and recommend how to improve other proposals. In addition to commenting, the AAN works with the agency throughout the year to ensure that the fee schedule accurately values the care provided by neurology providers.
While there are many proposals contained in the proposed rule that warrant AAN support, we remain deeply concerned that supplemental Medicare funding appropriated by Congress under the Consolidated Appropriations Act will expire in 2025 and cause a 2.8% decrease in reimbursement for all Medicare services, including neurological care. Further, Congress has not yet extended flexibilities associated with providing telehealth services beyond the end of 2024, and therefore CMS’ proposals for 2025 must reflect current statute. The AAN is committed to working with Congress to offset the detrimental impacts of cuts to the conversion factor and to extend telehealth flexibilities into 2025 and beyond. to ask them to fix the cuts to the MPFS and extend associated telehealth flexibilities.
Beyond the impacts to the conversion factor and expiration of certain flexibilities relating to telehealth, many of the policy proposals include significant changes that are consistent with long-standing AAN advocacy efforts. In support of maintaining permanent access to telehealth services, the AAN has previously provided CMS with a number of recommendations regarding permanent reforms that the agency may implement without further action from Congress to promote patient access to high-quality neurological care. In alignment with previous comments from the AAN, CMS is proposing modifications to key definitions that will permanently allow for coverage of audio-only telehealth services. For many years, the AAN has asked CMS to maintain access to audio-only telehealth, as it is an appropriate care modality for neurology, and many neurology patients are unable or unwilling to use video conferencing for a variety of reasons.
Further, the AAN led a broad coalition effort to urge CMS to ensure that parity is maintained between in-person and telehealth services. In response to stakeholder concerns, including the AAN’s, CMS declined to implement a slate of new outpatient telehealth office visit codes that if implemented in line with recommendations from the Relative Value Scale Update Committee (RUC) would have led to differential payment rates between in-person and virtual service.
Additionally, CMS is proposing a comprehensive analysis of the provisional codes on the Medicare Telehealth Services List before recategorizing any as permanent. The AAN supports this analysis and over the last several years has provided the agency with emerging evidence about a number of telehealth codes widely used in neurology.
To promote adequate payment for complex evaluation and management services (E/M), the AAN has previously asked CMS to consider circumstances where the office/outpatient E/M visit complexity add-on code G2211 could be appropriately billed with some same-day procedures. CMS is now proposing to allow the use of the G2211 add-on code when reported by the same practitioner on the same day as an annual wellness visit, vaccine administration, or any Medicare Part B preventative service.
In alignment with long-standing advocacy from the AAN concerning the inappropriate valuation of the global surgical packages, and the resultant reallocations due to fee schedule budget neutrality requirements, CMS is proposing to improve the accuracy of valuation and payment for global packages so that preoperative care, surgery, and post-operative care are more appropriately reimbursed. The AAN has been encouraging CMS to take these steps and is supportive of the proposed transfer of care modifiers and post-surgical complexity add-on code.
Going forward, the AAN will continue to engage with policymakers on Medicare physician payment and provide the agency with recommendations on how to modify policies to promote access to care and sustainability of neurologic practice.
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