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  • Access and Reimbursement for Infectious Disease Services

    Access and Payments

    Fair and adequate reimbursement for infectious diseases physicians is a key IDSA policy priority. The Society also advocates for access to appropriate treatments for patients with serious infections and for medical liability reform. IDSA’s positions on specific reimbursement and access issues that impact the practice of infectious diseases and Advocacy Alerts to key policy priorities are provided below. 

    Home Infusion Therapy

    IDSA's Efforts in Access and Reimbursement for ID Services


    IDSA Joins Other Medical Societies to Raise Awareness of Physicians’ Concerns Regarding the Implementation of MACRA

    IDSA jointly expresses concerns regarding the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). More specifically, comments are provided on the following overarching issues, ensuring that the implementation of MACRA does not disrupt the positive effect Alternative Payment Models (APMs) are having on beneficiaries' health in the public and private sector,  the need for a clear pathway for private sector models to meet the threshold for qualifying APMs under MACRA, virtual groups in the Merit-Based Incentive Payment System (MIPS) should be defined to help small, independent physician practices remain viable, and existing clinical quality improvement activities should satisfactorily meet MIPS requirements.

    IDSA Comments on 2016 Physician Quality Reporting System Feedback and Informal Review Processes

    IDSA has joined the AMA and 45 other medical societies in expressing concerns with the Centers for Medicare and Medicaid Services' inadequate feedback and informal review request processes. Specifically, the societies state issues with incomplete and inconsistent feedback, the lack of recourse for vendor transmission issues, inadequate assistance from QualityNet Help Desk, and the faulty informal review process.

    IDSA Letter to House Oversight Committee on Drug Pricing

    In advance of the House Government Oversight and Reform Committee hearing “Developments in the Prescription Drug Market,” IDSA sent a letter to Committee leaders related to broader issues regarding access to existing and new therapies for preventing and treating infectious diseases.

    IDSA provides comment on the FDA draft guidance for use of FMT to treat recurrent CDI

    IDSA responds the latest draft guidance issued by the FDA related to the use of FMT to treat recurrent CDI. In this draft guidance, the FDA has outlined its enforcement policy regarding IND requirements for FMT when use to treat RCDI. IDSA advocates for a finalized guidance that does not impose administrative burden on physicians who treat patients with RCDI with FMT.

    IDSA Responds to The Joint Commission's Proposed Standards for Antimicrobial Stewardship for Various Types of Healthcare Facilities

    IDSA responds to The Joint Commission's Proposed Standards for Antimicrobial Stewardship for various types of healthcare facilities that include Ambulatory Health Care Centers, Critical Access Hospitals, Hospitals, Nursing Homes, and Office-based Surgical Centers. Please review The Joint Commission’s Proposed Standards for Antimicrobial Stewardship to provide context to our comments.

    IDSA Comments on the CY2016 Physician Fee Schedule Final Rule

    IDSA provides comments on the Medicare Program Revisions to Payment Policies under the Physician Fee Schedule Final Rule for CY 2016 regarding the finalized changes for the Physician Quality Reporting System (PQRS) as well as the changes in the measure specifications that are concerning to IDSA. Additionally, IDSA also comments on improving payment accuracy for primary care and care management services and provisions related to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) specified in Medicare Access and CHIP Reauthorization Act (MACRA).

    IDSA Responds to Request for Information Regarding Alternative Payment Models and Merit-Based Incentive Programs (PDF)

    IDSA responds to the Center for Medicare and Medicaid's (CMS) request for information regarding implementation of alternative payment models (APMs) and merit-based incentive payment system (MIPS) called for in the Medicare Access and CHIP Reauthorization Act (MACRA). IDSA expresses the challenges infectious diseases specialists face within the current regulatory quality environment as well as recommendations on how to best implement the new MACRA regulations, being cognizant of the nuances of the ID specialty.

    Medical Groups Call for Changes to the Meaningful Use Program (PDF)

    IDSA joined the AMA and over 100 other national and state societies in a letter asking leaders in Congress to make changes to the meaningful use program prior to implementation of its next phase, Stage 3.

    IDSA Comments on Medicare Program Revisions to Proposed Payment Policies under the Physician Fee Schedule for CY 2015 (PDF)

    IDSA provides comments on the CY 2015 Physician Fee Schedule (PFS) proposed rule regarding changes to the code valuation process, Medicare Telehealth Services, Chronic Care Management, the Physician Quality Reporting System (PQRS), the Physician Resource-Use Feedback Program and the Value-Based Payment Modifier (VBM), the Medicare Shared Savings Program (MSSP) and the Physician Compare Website, among other Part B related issues.

    IDSA Jointly Provides Feedback on the National Quality Forum Measure Endorsement Process (PDF)

    IDSA has joined 31 other organizations to provide comments on the National Quality Forum (NQF) Measure Endorsement Process. The undersigned organizations believe that there are still deficiencies that need to be resolved, specifically around endorsement review timelines, the implementation of updated evaluation criteria, measure testing, and eMeasure requirements.

    IDSA Provides Comments on Medicare and Medicaid Program: Conditions of Participation for Home Health Agencies

    IDSA provides comments on the Medicare and Medicaid program: Conditions of Participation for Home Health Agencies proposed rule supporting the proposed changes that encourage a more patient-centered, outcome-oriented delivery of healthcare in the home setting. Furthermore, IDSA respectfully suggests the inclusion of infectious diseases specialists to help implement and maintain the infection control and prevention proposed condition in the rule.

    IDSA Leads Groups in Letter to CMS on Stewardship (PDF)

    IDSA was joined by 33 other organizations in a letter to the Centers for Medicare & Medicaid Services (CMS) advocating that hospitals and long-term care facilities be required to implement an antibiotic stewardship program (ASP) as a Condition of Participation (COP) in Medicare and Medicaid.  CMS is known to be actively considering the proposal.  The recommendation was also made by the President's Council of Advisors on Science and Technology (PCAST) in their recent report on combating antibiotic-resistant bacteria.

    IDSA Joins Cognitive Specialties Coalition in Supporting SGR Repeal and Modifications to Draft Legislation (PDF)

    IDSA signed onto a Cognitive Specialties Coalition providing input to the House and Senate committees working on a repeal of the Sustainable Growth Rate (SGR).  The letter expresses general support for a repeal of the SGR and more specifically calls on Congress to:  provide positive payment updates moving forward, adopt a threshold scoring model as opposed to a competitive one, and to include cognitive specialists in measures to encourage chronic care management and practice enhancements.

    IDSA Responds to Congressional Draft of SGR Repeal (PDF)

    IDSA wrote in support of the Senate Finance and House Ways and Means Committees' November 2013 discussion draft of a bill to repeal the Sustainable Growth Rate (SGR) and simplify current value-based payment programs.  The letter also called on Congress to consider periodic physician payment increases, as well as provided detailed recommendations on a host of issues in the congressional draft related to quality and assessment.

    IDSA Joins Coalition Appeals to CMS to ensure MA Beneficiaries Have Reliable Information When Choosing Health Insurance Options (PDF)

    As part of a collective of numerous state medical associations and national medical societies, IDSA urges the Centers for Medicare & Medicaid Services (CMS) to take immediate action to ensure that Medicare beneficiaries participating in Medicare Advantage (MA) plans have accurate and reliable information to make health insurance elections during the 2014 Open Enrollment period, and to address a lack of MA sponsor transparency on network adequacy.

    IDSA Comments on Medicare Program Revisions to Proposed Payment Policies under the Physician Fee Schedule for CY 2014

    IDSA provides comments on the CY 2014 Physician Fee Schedule (PFS) proposed rule regarding misvalued PFS codes, Medicare payments for services rendered in an office vs. facility, site of service data collection, complex chronic care management services, billing of Evaluation and Management Services, Clinical Laboratory Fee Schedule, Physician Compare website, Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier and Physician Feedback Program.

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