CMS's Part B Payment Policy: The Impact on Primary Care
Primary Care Collaborative
Nonprofit multi-stakeholder membership organization dedicated to primary care as the foundation of the health system
On July 16, 2024, The Primary Care Collaborative hosted a discussion with CMS leaders about how Medicare Part B payment policy could improve health by strengthening primary care.
Leaders from the Centers for Medicare and Medicaid Services (CMS) outlined how recently proposed changes to Medicare Part B payment policy could strengthen primary care.
Speakers included:
CMS invited attendees to submit additional questions and comments about the proposed rule and encouraged folks to respond to an RFI included the proposed regulation.
Following the presentation, PCC President and CEO Ann Greiner moderated a panel discussion reflecting on CMS’s presentation. The panel included:
The webinar event kicked off with remarks from CMS leaders. Introducing key elements of CMS’ new Physician Fee Schedule proposals, Dr. Seshamani explained that value-based primary care models have reduced emergency and hospital visits while meeting patient needs, and CMS plans to use these insights to create a new primary care payment bundle. This bundle, the new Advanced Primary Care Management (APCM) service will include adjustments for patient complexity to promote health equity and link services to quality measures for better Medicare outcomes.
Building on Dr. Seshamani’s comments, Director Fowler stated that the Innovation Center has been embedding various innovations into the Medicare program to support primary care, with a focus on collaboration across CMS. This includes the adoption of the ACO Investment Model as the Advanced Investment Payments Program as well as the upcoming ACO PC Flex Model. She too then touched upon the proposal for new APCMt codes to enhance care coordination and team-based care.
Dr. Jacobs explained the proposed changes in the 2025 Physician Fee Schedule related to primary care, focusing on the proposed APCM services. He detailed the three levels of APCM codes based on patient complexity and emphasized improvements in billing simplicity and care quality. He also highlighted requirements such as 24/7 care access, care management, and quality measurement. He encouraged the audience to thoroughly review proposed rules and weigh in with the agency by the close of the comment period, September 9th.
Dr. Rawal explained that this APCM bundle is the first step in a multi-year effort to enhance the nation's primary care infrastructure and improve patient outcomes. After highlighting the Innovation Center's commitment to primary care transformation through various models and collaboration with the Center for Medicare, Dr. Rawal detailed a Request for Information (RFI) seeking feedback on designing a future hybrid primary care payment system that incentivizes advanced team-based care. The RFI seeks feedback to specific questions on extending value-based care opportunities, alleviating billing requirements, supporting person-centered care, advancing health equity, and improving quality of care. She encouraged comments on the RFI.
Following this presentation, PCC President and CEO Ann Greiner moderated a panel discussion with health leaders reflecting on CMS’s presentation.
Dr. Navathe praised CMS for their thoughtful efforts to simplify coding and funding for primary care. However, he noted that the changes only apply to clinicians in advanced models, not all Medicare providers and questioned the extent of change and stressed the need to transform the primary care system nationwide. He highlighted that Medicare must lead this transformation.
Coombs also lauded CMS for their efforts to strengthen primary care, noting that a fee-for-service system limits progress in advancing health equity. While acknowledging the proposed APCM codes could be a step toward value-based care, she stressed they alone could not ensure equity without addressing underlying disparities and patient cost barriers. Coombs highlighted the need for a value-based system designed to focus on health equity and reduce beneficiary cost-sharing.
Dr. McKenzie also commended CMS for moving towards bundled payments and simplified coding, which she believes will reduce administrative burden and improve practice sustainability. However, she expressed concerns about cost-sharing barriers and emphasized the need for consistency in reporting and support for practice transformation. She also highlighted the importance of multi-payer adoption and ongoing support for physicians in implementing these changes.
The panel provided further insight as they answered various questions from meeting attendees. As the event concluded, Greiner stressed the importance of engagement from and mobilization of the primary care community as reforms are debated. CMS also encouraged folks to submit additional questions and comments about the proposed rule and respond to an RFI included the proposed regulation.