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PROPOSED CODE WILL HELP CMS VALUE COGNITIVE CARE SERVICES

August 21, 2023

Latest Advocacy News

  • The AAN submitted official comments in response to a long-awaited proposal to retire the National Coverage Determination that has been limiting access to beta-amyloid PET scans for more than a decade. The AAN has repeatedly urged the agency to retire this policy, given the recent approval of therapies directed against amyloid for the treatment of Alzheimer’s disease.
  • The AAN submitted comments on a proposed change to an existing National Coverage Determination regarding Percutaneous Transluminal Angioplasty (PTA) of the Carotid Artery Concurrent with Stenting. This proposal would broaden access to this procedure, and our comments commend CMS for their thoughtful analysis of evidence gathered during the Coverage with Evidence Development (CED) process. The AAN continues to push CMS to be more deliberate and efficient when applying and evaluating CED processes.
  • The AAN signed a letter as part of the Regulatory Relief Coalition in support of H.R. 4968, the Getting Over Lengthy Delays in Care As Required by Doctors (GOLD CARD) Act of 2023 introduced by Reps. Gonzalez (D-TX) and Burgess (R-TX). The legislation would allow physicians with high prior authorization approval rates to bypass prior authorization requirements imposed by Medicare Advantage plans.
  • In early August, the Partnership for Part D Access, a coalition the AAN works closely with, held two briefings to educate congressional staff and other stakeholders on Medicare’s Six Protected Classes Policy and its impact on the patient communities affected, including those with some of the most serious health conditions, including mental illness, cancer, HIV, epilepsy, Parkinson’s disease, and lupus.

Issue in Focus

CMS has proposed the implementation of the G2211 code in the 2024 Medicare Physician Fee Schedule (MPFS). This is an add-on code that would be billed alongside office/outpatient evaluation and management (E/M) visits to account for the complexity of patient care that is based on a clinician’s ongoing relationship with a patient. The code will support services provided during office visits that are related to ongoing care for a patient’s single, serious condition or a complex condition.

This code was first proposed in the 2021 MPFS. However, before it could be implemented, Congress recognized the need to provide relief to physicians during the COVID-19 pandemic. Since the MPFS is required to be budget neutral, Congress imposed a moratorium on implementation of this code until 2024 in order to fund that COVID-19 relief.

As the moratorium expires at the end of this year, CMS has once again proposed the implementation of the G2211 code. Due to budget neutrality, the implementation this year accounts for a majority of the cuts to the Relative Value Units across the board in the 2024 MPFS. This has caused several physician associations for those who would not be eligible to bill under this code to oppose its implementation. The AAN will be working hard to advocate with both CMS and members of Congress to ensure implementation of G2211 in 2024.

We will have more information on how you can get involved and what the AAN is doing in future editions of the Capitol Hill Report. For questions, contact us at advocacy@aan.com.

 

What We're Reading

  • CMS tweaks ACO REACH to stabilize model (HealthCareDive)
  • The Hidden Fee Costing Doctors Millions Every Year (ProPublica)
  • DOJ blasts industry attempt to delay Medicare drug price negotiations (The Hill)