Federal Policy Updates

For state specific policy head to State Policy Updates


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 lmcneely@thepcc.org 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 lmcneely@thepcc.org.

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

States Enact Bold Primary Care Measurement &Investment Legislation

Nineteen 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, CA, CT, DE, MA, MD, ME, NE, NH, NM, 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,

 

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

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

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.

 

 

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.
Go to top