Federal Policy Updates

For state specific policy head to State Policy Updates

PCC submits comments responding to AHRQ's proposed research framework

On April 21, 2022, PCC responded to a request for information on AHRQ's Proposed Patient-Centered Outcomes Research Trust Fund Strategic Framework. PCC provided several specific comments on AHRQ’s proposed framework and offered recommendations to ensure primary care research is foundational.

Some of the major topic areas addressed in the letter include ensuring research aligns with the Shared Principles of Primary Care, including research on primary care accessibility and team collaboration. Other research should focus on value-based payment models, health professions education, provider wellbeing and retention, and strengthening primary care research infrastructure.

PCC submits comment letter to CMS regarding access to care and coverage in Medicaid and CHIP

On April 18, 2022, PCC submitted a letter to CMS regarding a request for information on access to care and coverage for people enrolled in Medicaid and CHIP.

The Primary Care Collaborative (PCC) appreciates this opportunity to provide comments in response to CMS’s Request for Information on Access to Care and Coverage for People Enrolled in Medicaid and CHIP. PCC applauds CMS for pursuing Medicaid and CHIP rulemaking to enhance coverage, expand access to care, and improve availability and quality of primary care practices and health care providers.

PCC provides detailed responses to the specific questions included in the RFI. To summarize, PCC recommends that CMS:

  • Prioritize adoption of twelve-month continuous coverage for Medicaid and CHIP beneficiaries and to limit eligibility redeterminations;
  • Consider access to and investment in primary care in development of any future minimum standards;
  • Promote evidence-based models of primary care-behavioral health integration;
  • Issue comprehensive guidance to states on payment for evidence-based community health worker services;
  • Work with states to remove reimbursement barriers to the delivery of telemental health services to Medicaid beneficiaries by primary care practices; and
  • Require higher-quality data collection and reporting from states regarding race/ethnicity data and other demographic data.

PCC Submits Statement for Senate Finance Hearing: Protecting Youth Mental Health: Part II - Identifying and Addressing Barriers to Care

Please find attached PCC’s Statement for the Record, provided for today’s Senate Finance hearing: Protecting Youth Mental Health: Part II - Identifying and Addressing Barriers to Care.

The attached includes a series of policy recommendations relevant to integration of mental health and addiction care into primary care – recommendations that PCC believes are relevant for children and adults.

The PCC sends Behavioral Health Integration Recommendation Letter to HHS/CMS

Over the past two quarters of 2021, the PCC’s Behavioral Health Integration Workgroup has focused on developing payment recommendations that would support behavioral health integration in federal primary care payment.  The product of this work, a six-page letter to HHS Secretary Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure, was sent on January 26, 2022.

State Primary Care Investment Legislative Update

State Primary Care Investment Legislative Update:

  1. In Washington, SB 5589 was referred to the Health & Long Term Care Committee on January 10, 2022, which would charge the state Health Care Cost Transparency Board with measuring and reporting on primary care expenditures and progress toward increasing spending to 12 percent of total health care expenditures. If passed into law, by the end of 2022 the board would submit a preliminary report to the governor addressing primary care expenditures in the state of Washington.
  2. In Nebraska, LB 737 was referred to the Banking, Commerce and Insurance Committee on January 10, 2022 and would create a 15-member primary care investment council to:
    • Develop an appropriate definition for primary care investment.
    • Measure the current level of primary care investment, measured as a part of overall health care spending, by public and private payors in Nebraska.
    • Conduct a comparison of spending on primary care services and health outcomes in Nebraska with surrounding states and nationally.
    • Develop an appropriate target level of primary care investment by public and private payors in Nebraska.
    • Recommend strategies to achieve the target level of primary care investment through alternative payment models.
    • Identify the public health benefits and estimated cost savings that would result from meeting the target level of primary care investment though alternative payment models.
    • Identify solutions to barriers for Nebraska residents from accessing primary care and for health payors and medical providers from investing in primary care.

PCC endorses the Primary and Virtual Care Affordability Act (H.R.5541)

On Oct. 17, the PCC endorsed the bipartisan Primary and Virtual Care Affordability Act (H.R. 5541) in a letter to its cosponsors, Reps. Bradley Schneider (D-Ill.) and Brad Wenstrup (R-Ohio).  
According to the 2021 Kaiser Family Foundation Employer Health Benefits Survey of private and non-federal employers, approximately 28% depended on a high-deductible health plan with a savings option such as a Health Savings Account (HSA/HDHPs), but these plans bar coverage for many primary care services until patients meet their deductible.
High deductibles present barriers to needed primary care, and a temporary, pandemic-related provision that offers relief from deductibles for telehealth services expires Dec. 31, 2021.
HR 5541 would extend the telehealth waiver to Dec. 31, 2023, while simultaneously allowing employers and health plan sponsors the flexibility to also waive cost-sharing for in-person primary care. For PCC, this last provision was a key addition. 

CMS Innovation Center Update

Last week, the CMS Innovation Center released a refreshed strategic vision for the agency that hopes to achieve equitable outcomes through high-quality, affordable and person-centered care. In the document, the Innovation Center identifies and reflects on lessons learned from the previous decade of work, lays out broad objectives, and defines measures of progress to guide the work of the agency over the next decade.

The strategic objectives include:

  1. Drive Accountable Care
  2. Advance Health Equity
  3. Support Innovations
  4. Address Affordability
  5. Partner to Achieve System Transformation. 

In a public statement on the new strategy, PCC’s President and CEO, Ann Greiner, praised CMS leaders for “a bold vision and strategy for how to continue transforming the U.S. health system through innovation and a focus on equity" while noting “strong investments in comprehensive, whole-person primary care [are] crucial to its success.”

Legislative Update


  • Sens. Todd Young (R-Indiana) and Debbie Stabenow (D-Michigan) introduced the bipartisan Social Determinants Accelerator Act, a PCC-supported Senate companion bill to the Social Determinants Accelerator Act of 2021 (H.R.2503) initially introduced in the House.
  • On Oct. 8, the American Psychological Association (APA) submitted comments to the bipartisan social determinants of health (SDOH) caucus, highlighting the behavioral health elements faced by children and families, undocumented immigrants, and individuals without broadband access, and expressing the need for more uniform collection of SDOH data. In addition, the APA requests that CMS establish a new “G code” to better capture the utilization of SDOH specific services. The APA also endorses H.R. 2503.
  • The bipartisan Primary and Virtual Care Affordability Act (H.R. 5541) was recently introduced by Reps. Bradley Schneider (D-Illinois) and Brad Wenstrup (R-Ohio). It would allow high-deductible health plans with associated Health Savings Accounts to waive the deductible for telehealth and primary care services through the end of 2023.
  • PCC joined the Coalition to Improve Diagnosis, adding its signature to a letter to Senate leadership on the Appropriations Committee requesting increased funding to the Agency for Healthcare Research and Quality (AHRQ) for patient safety and diagnostic safety and quality.

Other Policy Updates


  • American Academy of Pediatrics released a new study that found that over 140,000 children experienced the death of a parent or grandparent caregiver during the COVID-19 pandemic and the risk of losing a caregiver was much higher for children of racial and ethnic minorities.
  • Health plans are taking on a larger role in addressing the social drivers of health to achieve health equity. In a report published in September, the Anthem Public Policy Institute explored the affordable housing crisis in California, with a focus on patients experiencing homelessness. The report discusses how Medicaid managed care plans can partner with states to provide resources for individuals experiencing homelessness. Additionally, Humana recently invested $25 million as part of a broad population health campaign to support affordable housing initiatives. PCC board member Dr. Nwando Olayiwola, Chief Health Equity Officer at Humana, said, “Humana is committed to addressing structural and root cause barriers to good health outside of the clinical setting, such as access to healthy food, transportation, social connections and stable housing, to help eliminate unjust differences in health.”
  • In a new paper titled “Health Care for Our Nation's Veterans: A Policy Paper From the American College of Physicians,” the American College of Physicians (ACP) advocates for the patient-centered medical home model for primary care delivery in the Veterans Health Administration by sustaining and strengthening the Patient-Aligned Care Team (PACT) model.
  • On Oct. 7, the National Partnership for Women and Families along with over 50 other reproductive justice and Black policy leaders signed a letter to democratic congressional leadership urging them to commit to extending postpartum Medicaid coverage to 12 months and include other equity-focused provisions found in the Black Maternal Health Momnibus Act of 2021 (H.R. 959) in the reconciliation process.
  • On Oct. 13, a number of PCC Executive Members (including American Academy of Family Physicians, American Academy of Pediatrics, American College of Physicians, Catalyst Health Network, and One Medical) signed on to a letter to executive leadership at the White House and HHS to include primary care physician practices in the ongoing COVID-19 vaccine rollout.
  • A partnership among Covered California (California’s ACA marketplace), California Public Employees’ Retirement System (CalPERS) and PCC Executive Member Purchaser Business Group on Health (PBGH) will launch a pilot program beginning in 2022 to test practice-level measurement using 11 advanced primary care measures developed by the California Quality Collaborative

Primary Care and COVID-19 Vaccines

At the time of this writing, the processes of approving COVID-19 booster shots for eligible populations and initial doses for children between the ages of 5 and 11 have moved forward.
In anticipation of the authorization of the COVID-19 vaccine for children 5 to 11, the White House released on Oct. 20 a plan to ensure a timely and equitable distribution of the child doses. Primary care will play a substantial role in the distribution from the onset, with the White House planning to engage over 25,000 pediatric and primary care practices in vaccine administration. This includes providing appropriate training and working with states to increase the number of practices enrolled to administer the vaccine.
The American Academy of Pediatrics and others in primary care are eager to play a greater role in vaccine administration. This is coming at a time when vaccine hesitancy continues and as primary care is seen as the most trusted source of COVID-19 information. Now the federal government needs to compensate primary care clinicians for vaccine counseling, along with continued support for vaccine administration. 

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