Federal Policy Updates

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.

As of today, eighteen states have taken steps to measure primary care spending in the state – a key step to strengthening primary care. 

Since 2018, PCC has served as a backbone organization for burgeoning movement to measure primary care spending and increase investment in primary care. 2022’s state legislative sessions reveal progress is accelerating

• As of June 2022, there are 18 states that have measured or committed to measure primary care spending, with more possible (CO, CACT, DE, MA, MD, ME, NE, NH, OR, RI, UT, VT, WA; Medicaid only: NJ, WV, OK, HI).

• 6 states have set targets for primary care spending in legislation without growing total cost of care (CO, CT, DE, OR, RI, WA).
• In 2022 alone, new legislation was enacted or passed in California, Connecticut, Maryland, Nebraska, New York, Oklahoma, Utah, Washington. 

To hear more about this growing movement in state Capitols around the country,

• check out this June 22nd Webinar featuring PCC President and CEO Ann Greiner, sponsored by the Milbank Memorial Fund, PCC and the American Academy of Family Physicians
• visit PCC’s State Primary Care Investment webpage

Approximately 700 women die annually in the United States because of pregnancy or its complications and according to the Centers for Disease Control and Prevention (CDC), approximately 60 percent of pregnancy related deaths are considered preventable. Building on PCC’s advocacy to ensure health across the lifespan, PCC has offered a letter of support for the Helping MOMS Act of 2021 (H.R. 3345), which would permanently extend 12-months of continuous Medicaid coverage postpartum and temporarily increase the Federal Medical Assistance Percentage (i.e., federal matching rate) for pregnancy-related services in states that choose to do so.

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.