The Centers for Medicare & Medicaid Services’ proposal to pay explicitly for advanced care planning services under the physician fee schedule will help ensure that Medicare beneficiaries are able to develop advanced care plans with their medical care providers, AHA Executive Vice President Tom Nickels told the agency today, commenting on the proposed PFS rule for calendar year 2016. AHA also voiced support for CMS’s proposal to add two new codes to its list of approved Medicare telehealth services and encouraged the agency to consider adding other services in future rulemaking. In addition, AHA said it supports CMS’s creation of new exceptions to the Stark prohibition on physician self-referral, and urged the agency to “create an exception that would protect hospitals and physicians who enter into financial arrangements necessary to building clinically and financially integrated models of care.” With respect to physician quality measurement, AHA applauded CMS’s proposal to exempt participants in certain Centers for Medicare and Medicaid Innovation programs from the CY 2017 and 2018 value-based payment modifier, but strongly urged the agency to also exempt Medicare Shared Savings Program participants. AHA also urged CMS not to expand mandatory CAHPS reporting to groups smaller than 100 eligible professionals until it allows the use of more modern and economical methods to collect survey data, and shortens the “excessively long” CAHPS survey instrument.

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