In comments filed yesterday with the Centers for Medicare & Medicaid Services (CMS), the National Partnership for Women & Families commends proposed updates to the Medicare Physician Fee Schedule and Part B, and particularly applauds CMS’ proposal to reimburse providers for high-quality, effective advance care planning. In the letter, the National Partnership emphasizes that meaningful collaboration and partnership with patients and families must be at the heart of advance care planning. The comments encourage CMS to tie reimbursement to patient-reported quality measures to ensure that providers are held accountable both for delivering high-quality advance care planning and for delivering health care that aligns with patient preferences.

“The changes CMS proposed to the Medicare Physician Fee Schedule and Part B hold promise for improving the experience and quality of care for beneficiaries. Updating how physicians are reimbursed to prioritize delivery of care that is driven by the needs and preferences of the patient can help us reward quality and value, rather than volume,” said National Partnership for Women & Families President Debra L. Ness. “CMS’ proposed changes help reduce some of the barriers to ensuring that patients and families are considered partners in their own health care planning and in delivery system and payment transformation.”

The proposed rule also takes first steps toward implementation of key provisions of the Medicare Access and CHIP Reauthorization Act (MACRA) by requesting input on clinical practice improvement activities and Alternative Payment Models (APMs). In its letter, the National Partnership recommends key principles CMS should employ when implementing requirements for Patient Centered Medical Homes (PCMHs), clinical practice improvement activities, and APMs under MACRA. For example, the letter encourages CMS to prioritize ready access to care, coordination of care, meaningful use of health IT and a strong commitment to beneficiary engagement in the design of both PCMHs and APMs.

CMS’ proposed updates to the Physician Fee Schedule and Part B also call for expanding the Comprehensive Primary Care (CPC) Initiative, with which the National Partnership has been involved since the initiative’s inception. The letter expresses strong support for this expansion and encourages CMS to provide robust technical assistance to help practices meaningfully engage patients and families in care transformation and quality improvement efforts.

The National Partnership also commends a number of proposals to improve consumer access to and ability to use health care quality data, including making the Physician Compare website more user-friendly for patients and families so they can use individual clinician level quality data to make decisions about their care and choice of provider.

The letter is available here.