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Palliative Care News

C-TAC Urges CMS to Better Address Caregiver Support, Social Determinants in Proposed 2024 Physician Fee Schedule

By Holly Vossel| October 4, 2023
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The Coalition to Transform Advanced Care (C-TAC) recently called for greater support for family caregivers and social determinants of health in fee-for-service payment models that include palliative care.

The U.S. Centers for Medicare & Medicaid Services (CMS) has proposed changes to the 2024 physician fee schedule (PFS) and other Medicare Part B payment policies. The proposed rule lacks reimbursement and resources for caregivers of serious illness patients and families, according to C-TAC.

“The annual Physician Fee Schedule includes updates on what services will be included and paid for by Medicare Part B. We are excited that with this proposed rule, all those components, with the exception of assessing for caregiver burden, now have payment associated with them,” C-TAC stated in a letter to the agency shared with Hospice News.

CMS has proposed new reimbursement channels under the PFS that include chronic care management and transitional care management services.

While the changes pay for “most elements” of serious illness care, the payment models need more “comprehensive assessment” coverage, according to C-TAC. Additional reimbursement pathways are needed to increase palliative and primary care integration across the health continuum, as well as improve quality outcomes among patients and families, the organization stated.

C-TAC is a national nonprofit coalition of more than 200 health care providers, clinicians, health plans and patient and consumer advocacy groups aimed at improving serious illness care in the United States.

The organization is urging CMS to expand both the definition of a “caregiver” and consider additional payment avenues that would support their training. The agency’s current definition includes more than family members, friends or neighbors, but some of the terms can be restrictive, according to C-TAC.

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The organization recommends removing the “proxy” and “guardian” categories from CMS’ definition, in addition to expanding payment for caregiver training services (CTS). Some palliative patients hire paid caregivers and do not have a proxy or guardian involved in their care, C-TAC indicated.

“Patients may have a legal proxy or guardian, but that is not always the same person as the one helping with their practical care and, therefore, the one needing training,” C-TAC said. “Often the legal guardian or proxy is not even located near the patient, or is nearby but does not have a role in their day-to-day care. Excluding these designations from the definition will help ensure CTS is only for those caregivers

directly involved in the patient’s care. If a guardian or proxy is also a caregiver, that person could qualify for CTS.”

Family caregivers often lack the training and education needed to support seriously ill patients, the organization stated. Providing training to unpaid caregivers would help improve care delivery and quality by better preparing these individuals for the nuances of serious illness care, according to C-TAC.

CMS in its proposed changes to PFS also included new billing codes for services that address health-related social needs. Processes included in the proposed updates require physicians to assess patients’ social determinants of health (SDOH).

These assessments could include other components such as community health integration services, financial concerns, caregiver burdens and advance care planning discussions, C-TAC indicated.

Other CMS’ changes to the physician fee schedule include components to support the use of audio-only telehealth visits for community health integration services. Some older, seriously ill patients may lack internet services for video visits or may not be familiar with certain technologies, C-TAC stated in the letter.

The PFS changes are important to move the needle forward in improved experiences on both the patient and provider side, the organization added.

“We hope that future rule-making will also require providers to address any identified SDOH needs and, ultimately, make and track referrals to ensure patients get the services they were referred to,” C-TAC stated. “Additional payment is necessary to add this important activity to providers’ already busy clinical workflow.”

Holly Vossel

Holly Vossel, senior reporter for Hospice News, is a word nerd and a hunter of facts with reporting roots sprouting in 2006. She is passionate about writing with an impactful purpose, and developed an interest in health care coverage in 2015. A layered onion of multifaceted traits, her interests include book reading, hiking with her dog, roller skating, camping, kayaking and creative writing.

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