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IDSA Advocates for Closing ID Care Payment Gaps

in 2021 Physician Fee Schedule and Quality Payment Program Proposed Rule

In a letter to the Centers for Medicare & Medicaid Services, the Infectious Diseases Society of America highlighted provisions in the agency’s 2021 Medicare Physician Fee Schedule and Quality Payment Program proposed rule affecting payments to infectious diseases physicians as well as access to infectious diseases specialty care. Among the key points addressed, the letter:

  • Encourages CMS to work with Congress to mitigate the reduction in Medicare payments to ID physicians;
  • Proposes that CMS issue within the fee schedule final rule a professional services claims-based payment enhancement to help recognize the enhanced, non-separately reimbursable work performed by physicians during the COVID-19 public health emergency;
  • Supports an add-on billing code addressing cognitive care expertise and requests that CMS allow reporting of the code in conjunction with inpatient evaluation and management codes until those services are revalued in a fee schedule;
  • Urges CMS to remove inpatient hospital visit limitations, allowing clinicians to make care decisions based on clinical needs of their patients;
  • Strongly recommends that CMS establish policies making audio-only telephone evaluation and management visits a permanent fixture in the Medicare program, and that audio-only and in-person visits be reimbursed equally;
  • Discusses possible coding and payment for virtual care services that improve patient care but do not necessarily involve direct patient care, including antimicrobial stewardship and infection control and prevention;
  • Expresses concern that a proposed 5% cut to independent laboratory services limits the ability of clinical laboratories to develop, innovate and offer critical diagnostic tests following previous cuts to reimbursement in 2019 and 2020 and recommends strategies to alleviate payment reductions to vital laboratory services;
  • Suggests that CMS consider the use of population health measures that incorporate both administrative and clinical data to account for clinical circumstances that cannot be captured by administrative claims-based data alone;
  • Urges CMS to increase the weight of “Implementation of an Antibiotic Stewardship Program ” to a “high-weight” activity as it requires significant time and resources.

The letter also supports CMS’ proposal to double the calculated complex patient bonus for performance year 2020.  IDSA appreciates CMS’ efforts to recognize that practicing medicine during a pandemic is increasingly complex and efforts such as quality reporting, even under normal circumstances, are extremely difficult with the top priority being patient care. 

Read the full comment letter, and visit the Medicare section of IDSA’s website for more updates on the Medicare program and payment policy information.

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