pmda public policy

Advance Care Planning Codes
​2015 CMS Includes Codes for ACP

• EM Codes = 99497 and 99498
• Status = I (Inactive)

July 8, 2016 CMS Proposes Inclusion in Final Physician Fee Schedule

• Status = A (Active)
• Medicare carriers would have to develop local policy
• Could be billed along with EM visit codes
• Applicable to the nursing facility setting

​PMDA ACP Position

• PMDA supports inclusion of EM codes 99497-8 into the physician fee schedule as active codes.
• ACP is a crucial component of quality medical care and should be reimbursed. ACP is a part of patient centered care.
• PMDA urges carriers to adopt coverage policies for these codes.

​PMDA ACP Actions

• Monitoring for final CMS PFS
• Planned education for members

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CMS Proposed Reforms of Nursing Facility Regulations
CMS NF Regulation Reform

• July 2015, CMS releases proposed regulatory reforms for NF that would update the 1987 OBRA based regulations. View the proposal.
• AMDA & PMDA both submitted comments
• Infection control & antimicrobial stewardship changes
  1. Infection Control & Prevention Officer (ICPO)
     • “Major responsibility”
     • FTE requirement variable based on facility
     • FTE estimates = 15% for 100 bed facility
  2. Antimicrobial Stewardship Program would be required
• Requirement for face to face visit before transferring a resident
• Would allow dieticians to write orders for therapeutic diets

PMDA Regulatory Reform Position

• PMDA submitted detailed comments to CMS. Read the comments.
• Opposed the requirement for a FTF visit prior to transferring a resident
• Opposed ability of dieticians to write orders independent of physicians

​PMDA Regulatory Reform Actions

• Planned education for members

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Physician Workforce
PMDA Members Note Challenges Recruiting Physicians

• Particularly LTC and in rural areas

PMDA Workforce Position

• No position established yet

​PMDA Workforce Actions

• Work group formation
• Literature scan to define scope and identify strategies
• Outreach to Leading Age and AGS

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Additional Resources
​June 2014 – PA Dept of Health FAQ on ACT 122 – related to use of outside laboratories in LTC