AAN Advocacy Gains Chronic Care Management Reimbursement for Neurologists

July 21, 2014

Regulatory Corner
By Daneen Grooms, AAN Regulatory Affairs Manager

Chronic Care Management Code Not Restricted to Primary Care
As Regulatory Affairs Manager, I have the pleasure of meeting with officials from the Centers for Medicare & Medicaid Services (CMS), developing relationships with patient advocacy groups, and networking with colleagues from other medical societies. I also devote time to reading regulations from CMS and other agencies that impact neurology and this year was no exception.

On July 3, CMS gave neurology some welcome news in the release of the 2015 Medicare Physician Fee Schedule (MPFS) proposed rule. After two years of intense advocacy with CMS, neurologists who treat patients with multiple chronic conditions and meet the chronic care management (CCM) code reporting requirements can be reimbursed for the non-face-to-face care management involved for these beneficiaries. For 2015, CMS is proposing a payment rate of $43.67 for the CCM code, which can be billed once per month per qualified patient.  

To ensure that neurologists would be able to receive payment for CCM, Dr. Bruce Sigsbee and I met with CMS staff several times over the last couple of years. During our meetings, we urged CMS to not tie CCM to an annual wellness visit or patient-centered medical home, which focus on primary care. CMS also wanted to require physicians to employ advanced practice providers. We objected to each of these requirements because our concern was that neurologists who serve as the principal care provider and coordinate the care of patients with chronic conditions like ALS or Parkinson's disease would be precluded from billing these services.

While I support CMS not finalizing these requirements, I am concerned they are continuing to require that CCM must be furnished with the use of an electronic health record (EHR), other health IT, or health information exchange platform. Dr. Sigsbee and I objected to this requirement when we met with CMS, citing complete interoperability is not yet attainable for many physicians. I will continue to reiterate our objection to this requirement in our comment letter.

In addition, the proposed rule includes two other provisions that AAN has long championed for and we appreciate CMS' responsiveness to our concerns. First, CMS is proposing to eliminate the 10- and 90-day global periods for surgical procedures by 2018. A global package is a single payment that includes the procedure and the services typically provided in the periods immediately before and after the procedure. For years, the AAN has been pushing for elimination of these global periods. I am glad to see that our persistence and many comment letters have paid off and that CMS agrees. Eliminating these global periods would not only reduce unwarranted payments, but would also eliminate disparities between the payment for E/M services in global periods and those furnished individually. If CMS can withstand the political pressure this proposal is going to attract, surgeons will be paid fairly for the services they render, and some funds will be redistributed to the rest of the fee schedule.

Second, in response to pressure from the AAN, CMS is proposing to change their process and allow public comment on values for new and revised codes before they are finalized, starting in 2016. I am very supportive of this proposal and commend CMS for looking into how they can make this process more equitable and transparent. As you know, neurology was directly impacted in 2013 when CMS made drastic cuts to the NCS/EMG codes with virtually no notice. The timing of these cuts left little time for neurologists to prepare their practice for the changes. Over the last two years, the AAN has voiced our serious concerns to both CMS and Congress about the current process and the need to allow for physician input before codes are finalized. I will be sure to reiterate the AAN's strong support of this proposed change and others in our comment letter due around Labor Day. 

Read the AAN's analysis of the 2015 Medicare Physician Fee Schedule (MPFS) proposed rule to learn about other provisions affecting neurology.

Neurologists' Influence
by Mike Amery, Esq., AAN Legislative Counsel

Over the last two weeks, the AAN DC office welcomed a couple of AAN members to DC to lobby on behalf of neurology and saw a potential breakthrough for our message that Congress needs to focus on the access to care needs for patients with neurologic conditions. 

First, BrainPAC Executive Committee member Mark Kozinn, MD, came up from Atlanta to attend some congressional fundraisers and to visit with many of the members of the Georgia delegation including meeting personally with his congressman, Rep. Phil Gingrey, MD (R), and physician champion Rep. Tom Price, MD, (R).

Dr. Kozinn was followed last week by Mike Gruenthal, MD, of Albany, New York. Gruenthal personally thanked his member of Congress Rep. Paul Tonko (D) for signing on to the AAN's legislation HR 1838, which would add neurology to the Medicaid Bump provision of the Affordable Care Act.

We really appreciated the visits by Drs. Kozinn and Gruenthal as we continue to press Congress to support neurology.

A Breakthrough?
We never know where, when, or with whom we will make a breakthrough. A Senate hearing last week may have been one of those developments, as the Senate Finance Committee held a hearing on chronic care.

Throughout the hearing, it was clear committee Chair Ron Wyden (D-OR) and other members of the committee were most interested in patient conditions that are primarily cared for by neurologists. There were five witnesses, including Mrs. Mary Margaret Lehmann from Minnesota, who cares for her husband who suffers from Alzheimer's disease. About an hour and 20 minutes into the hearing she was asked about care givers and she said, “My husband's primary care provider is his neurologist.”

Members of the AAN have been bringing that same message to the Hill for many years now. It was nice to see a member of the patient community making the same argument before the members and staff of this important committee. 

Pennsylvania Neurologists Team Up For HUGE Scope of Practice Victory, 
by Tim Miller, Sr. Program Mgr, Communications and State Advocacy

In a team effort that would have made late Pittsburgh Steelers coaching legend Chuck Noll proud, neurologists in Pennsylvania recently saw the fruits of their advocacy labor come to fruition.

Pennsylvania audiologists had been seeking state legislation to add interoperative monitoring (IOM) of the central nervous system, spinal cord, and cranial nerve function to their scope of practice, without properly certified physician supervision.

The Pennsylvania Neurological Society, with assistance from the Pennsylvania Medical Society and the AAN, put together a coordinated effort to educate legislators, legislative staff, and other stakeholders about the patient safety concerns that would exist under the audiology proposal. The Pennsylvania Assembly agreed and passed amended language requiring physician supervision of audiologists performing IOM. 

“I'm so proud of what we accomplished,” said Brad Klein, MD, MBA, while also giving credit to colleague Partha Thirumala, MD. “This just proves we (the Pennsylvania Neurological Society) can make a change to the system with a coordinated effort, passion to do the right thing, and a little political know-how.”

Introduced in May 2013, this prolonged effort was not a small task. As Klein noted, efforts included educating the state medical society and coordinating with lobbyists on their behalf, testifying in front of the health committee in the Pennsylvania Assembly, and multiple calls and teleconferences with key stakeholders. Governor Tom Corbett signed the legislation July 2.
This is a great example of how state neurologic societies can make a difference at the local level. Coordination, education and communication are three key ingredients to advocacy success.


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