Federal Policy Updates

For state specific policy head to State Policy Updates

PCC and Better Health – NOW Campaign submit comments on Medicaid eligibility and enrollment proposed rule

In a letter submitted November 8, PCC and the Better Health-NOW Campaign commented on specific provisions of a Medicaid and CHIP eligibility and enrollment proposed rule aimed at enhancing continuity of primary care and reducing cost-sharing barriers.

Health coverage disruptions, and cost barriers can disrupt the continuity of care that is essential to quality primary care and improved health outcomes, especially for the vulnerable individuals and families who are eligible for Medicaid and CHIP.

The letter offers specific support for:

  • Streamlined eligibility and redetermination in Medicaid and CHIP
  • Improved eligibility processes for Medicare Savings Programs, which defray Medicare premium and cost sharing costs
  • Prohibitions on lock-outs and waiting periods in state CHIP programs

The letter goes on to recommend broader improvements urgently needed to enhance primary care investment and support behavioral health integration in Medicaid and CHIP.

Read the full letter here.

PCC Joins 800 Stakeholders, Urging Congress to Renew Advanced Payment Model Incentives

PCC joined more than 800 health care associations, accountable care organizations (ACOs), medical practices, and health systems to urge Congressional leaders to extend incentive payments meant to encourage participation in risk-bearing alternative payment models (APMs), in a letter released on September 28, 2022. Those incentives expire at the end of the year unless Congress acts.

Congress in 2015 created a 5 percent incentive payment to support  new payment models. While there are nearly 300,000 clinicians expected to receive the incentive this year, that number is far below Congressional expectations when the incentives were established. Therefore, the letter calls on lawmakers to extend the incentives to allow more time for a greater number of practices to move into APMs, which have shown an ability to improve quality and lower overall cost of care. 

Failure to renew the incentives could deter participation in a range of primary care payment reform initiatives, including the Primary Care First, state primary care payment reform initiatives like the Maryland Primary Care Program, the Medicare Shared Savings Program, and private sector primary care initiatives. “Ending these important incentive payments would discourage future participation in models that have seen growing uptake in recent years,” the letter states. “The incentive payments...provide additional resources that can be used to expand services beyond traditional fee-for-service.” 

Read the full letter here.

PCC joins 90+ organizations in sign-on letter in support of the Building a Sustainable Workforce for Healthy Communities Act (H.R. 8151/S. 3479)

On September 8, 2022, PCC joined a letter of support to Congressional leadership, alongside 90+ local, state and national organizations, urging members of Congress to pass H.R. 8151/S. 3479, the Building a Sustainable Workforce for Healthy Communities Act. The bipartisan legislation would strengthen federal support for community health workers to improve health outcomes in medically underserved communities.

PCC’s support for this legislation illustrates the organization’s commitment to equity by addressing social drivers of health.

Read the full letter here.

For more on the intersection of primary care and health equity, take a look at our May 2021 report with the National Center for Primary Care at Morehouse School of Medicine: Primary Care: A Key Lever to Advance Health Equity

PCC’s Better Health Now Campaign Submits Comments to Senate Committee Leadership on the Telemental Health Access Act

PCC and the Better Health – NOW Campaign support key provisions of the Telemental Health Access Act discussion draft
Telehealth technologies have the potential to contribute to safe, high-quality primary care particularly if utilized in coordination with an individual’s medical home. PCC and the Better Health – NOW Campaign support key provisions of the Telemental Health Access Act discussion draft including those described below:

  • PCC supports removing the requirement for in-person visit for tele-mental health visits and leaving the decision of the appropriate modality of tele-mental health care to the professionalism and training of the care team and the patient.
  • PCC supports provisions enabling primary care practices to rely on audio-only telemental health services beyond the pandemic.
  • PCC urges the Committee to work with CMS to limit the burden on practices associated with any modifier.
  • PCC supports requiring the Secretary of HHS to issue guidance on provision of Medicare telehealth services for individuals with limited English proficiency.

PCC Sends Letter of Support for H.R. 3345, the Helping MOMS Act of 2021

PCC supports the Helping MOMS Act, as an important step to confronting the maternal mortality crisis.

PCC supports H.R. 3345 as an important step to confronting the maternal mortality crisis. It would:
• Extend Medicaid postpartum coverage for 12 months on a permanent basis; and
• Temporarily increase the Federal Medical Assistance Percentage (i.e., federal matching rate) for pregnancy-related services in states that choose to do so.

Read the full letter here.

PCC and Better Health--Now submit Comments to CMS on Medicare Advantage Request for Information

Medicare Advantage (MA) Is growing part of Medicare and influencing new primary care models. In a August 31st response to a recent CMS Request for Information , PCC’s Better Health-NOW Campaign called for policy changes that reform both how much we invest in primary care as well as how we pay for it – to assure everyone has access to primary care they can trust. PCC’s letter:

  • Measure primary care spending and its impact on Medicare Advantage beneficiary outcomes.
  • Improve CMS capacity to collect, standardize, report, and where practicable and effective, stratify data to facilitate comparisons across all parts of Medicare (traditional fee-for-service, ACOs/MSSP, and Medicare Advantage).
  • Use plan design and payment reform to encourage proactive care and to remove cost and other barriers to beneficiaries accessing preventive care, integrated behavioral health care and chronic care.
  • Encourage MA plans to use primary care payment reform and investment to drive practice level innovation, support comprehensive primary care, and reduce administrative burden, as recommended in the 2021 National Academies of Science, Engineering, and Medicine (NASEM) report, Implementing High-Quality Primary Care.
  • CMS should use a small, robust, valid set of quality measures and incentives that reflect the contribution of primary care. Quality measurement should facilitate comparison across all parts of the Medicare program. Performance incentives should reward both high achievement and improvement in beneficiary outcomes and experience of care in all communities with respect to behavioral and physical health.

Read the full letter here.

PCC and Better Health--Now Responds to Medicare Physician Fee Schedule Proposed Rule

On September 5, PCC and Better Health-NOW responded to CMS’ latest physician payment rule with a call for big policy change to strengthen primary care. The letter praised constructive CMS proposals to strengthen behavioral health integration, vaccination reimbursement, and access to accountable care in underserved communities, but insisted that the agency must move much more boldly to support whole person primary care in all communities
Medicare Part B’s reliance on fee-based payment as the primary means of primary care payment systematically undercuts investment in the sector even as it undermines health equity. Yet to date, Medicare, the nation’s largest payer, has yet to implement widely available alternatives to the fee-for-service reimbursement in primary care. The PCC/BHN letter argued that primary care practices need pathways to rapidly transition from a predominantly fee-for-service model to a predominantly population-based prospective payment (hybrid) model. The BHN Campaign specifically called for a primary care hybrid payment option available within the MSSP and suggested that CMS seek public input to inform the design and implementation of such an option, as well as other possible pathways to support population-based, prospective payment in Medicare.

Read the full letter here

Better Health – NOW Campaign Calls for Bold Leadership from HHS on Primary Care Payment, Investment

On August 1st, the Primary Care Collaborative's Better Health - NOW Campaign submitted consensus recommendations to shape a forthcoming federal Action Plan to Strengthen Primary Health Care - now under development by the Office of Assistant Secretary of Health, Admiral Rachel L. Levine, MD.

Review the Campaign’s comments on the new HHS Primary Care Initiative attached below.

Read the full letter here.

CMS’ Payment Reg: Promising Policies, but Tied to a Flawed System

On July 1st CMS released several constructive new proposals in its annual Medicare Part B payment Notice of Proposed Rulemaking. Provisions include

  • New flexibilities to support behavioral health integration in primary care;
  • Advanced Investment Payments to form ACOs in underserved communities;
  • A series of steps to help make the Medicare Shared Savings Program better for practices  overall and particularly in underserved communities;
  • Coverage for medically necessary dental care in Medicare for beneficiaries with certain conditions.

Unfortunately CMS’s helpful proposals remain rooted in a predominantly fee-based framework that under-resources primary care and fails to support health equity. Across-the-board reductions to Medicare Part B practices, now looming January 1st, further underscore the urgent need for new solutions.

Working with Better Health – NOW Campaign participants, the PCC team is developing comments that support worthwhile CMS proposals, while urging bolder reforms aligned with our Concordance Recommendations for Primary Care Investment and Payment. Draft comments will be circulated for feedback from Better Health – NOW Campaign Participant organizations by mid-August.  If your organization is not yet a Better Health – NOW Campaign Participant, now is a great time to get engaged. Please contact [email protected] to learn how.

PCC encourages Executive Members to consider submitting their own comments to CMS. Comments are due to CMS 11:59 pm Tuesday, September 6th.

HHS Requests Stakeholder Input on Strengthening Primary Care

The Office of the Assistant Secretary for Health (OASH) is coordinating development of an initial Health and Human Services (HHS) Action Plan to Strengthen Primary Health Care. OASH seeks input from members of the public via a Request for Information (RFI) about what the Federal government could do to strengthen primary health care in the United States. In particular, OASH seeks innovations, models, solutions to barriers, and possible HHS actions that may strengthen primary health care to promote health equity, reduce health disparities, and improve health care access and health outcomes. PCC's Better Health - NOW Campaign will be submitting comments.

To learn more about PCC’s Better Health-NOW Campaign to strengthen primary care, click here or contact [email protected].

Responses to the RFI must be submitted by August 1. For additional information on the RfI, see the Federal Register notice.

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