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CMS proposes physician reimbursement for end-of-life discussions

July 8, 2015
by Pamela Tabar, Editor-in-Chief
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Physicians should be reimbursed under Medicare for end-of-life care consultations, including discussions about treatment options, according to a proposed rule document released late Wednesday by the Centers for Medicare & Medicaid Services (CMS). If the rule becomes final, the reimbursements and quality incentives would begin in 2019, the document estimates.

The landmark payment change is part of an 815-page document of proposed changes to CMS’ CY 2016 Physician Fee Schedule, part of which involves the designation of a new Current Procedural Terminology (CPT) billing code for advanced care planning (ACP) services reimbursement under Medicare. The proposal has been applauded by more than 65 provider organizations, from the American Medical Association to the National Hospice and Palliative Care Organization and the American Academy of Hospice and Palliative Medicine.

The Society for Post-Acute and Long-Term Care Medicine (AMDA) strongly approves the move: “Post-acute and long-term care practitioners provide quality and thoughtful care and family members and friends of very ill patients will receive greater peace of mind that the care their loved ones receive is based on adequate medical information, collaborative goal setting, as well as respect for personal wishes and values in order to maximize comfort and quality of life,” said AMDA President Naushira Pandya, MD, CMD.

Adds the American Academy of Hospice and Palliative Medicine, in its support statement: “We urge CMS to finalize its ACP services proposal. Once implemented, CMS should monitor how ACP services are being delivered and assess their impact on beneficiary quality of life and effectiveness of care.”

Historically, a lack of physician reimbursement and standards for end-of-life care conversations have contributed to a disjointed approach to advanced care planning. The milestone 2014 Institute of Medicine report, “Dying in America: Improving Quality and Honoring Individual Preferences Near the End of Life,” strongly urged long-term care professionals and physician groups to reassess current practices and approaches to care of the dying in light of person-centered care, noting that many times the medical treatment course is placed above the dying patient’s wishes or involvement.

In March, key national policy-makers and leading medical groups gathered in Washington, D.C. for an intensive, day-long symposium to discuss national action plans for improving quality services for end-of-life care. “We are in the business of changing the way people experience healthcare. We try to make sure the care they receive is consistent with their individual values, goals and preferences,” said Peggy Maguire, JD, senior vice president for corporate accountability and chief of staff at Cambia Health Solutions, in her presentation at the symposium. “To treat the whole person and not just the patient and not just a body part, we need to think about what they need from both a medical and psychosocial lens. There have been tremendous silos between health services and social services. But it doesn’t have to be that way.”

|Read our coverage of the Washington, D.C. End-of-Life Care symposium|

The focus on person-centered care and the longitudinal view of the care chain logicially should include professional counseling and discussions on end-of-life options, which could lead to better informed choices by the dying, as well as lessened anxieties for families and caregivers, say many organizations.  AMDA calls advanced care planning “a necessary and important part of providing quality post-acute and long-term care as the majority of the patient population lives with multiple chronic conditions and/or is near the end of life.”

The proposed changes also could spur more educational resources for families dealing with the imminent death of a loved one, while preserving the patient’s right to choose among various treatment options, notes a 2014 JAMA article authored by the American College of Physicians High Value Care Task Force. Productive and open communications between professional medical teams and those near the end of life are crucial to ensure that patients understand the nature of their illness, to provide patients an educated way to retain control over their own care preferences and to improve clinical outcomes during the last phases of life.

The proposed new CPT code for advanced care planning also has other potential benefits, including providing a way for CMS to track how end-of-life care is being delivered and what impact those services have on quality of life for patient in their final stages of life.

The public comment period on the advanced care planning element and other proposed changes to the physician fee schedule is open until September 8, 2015.

The entire proposed rule for chages under the CY 2016 Physician Fee Schedule can be accessed here; the advanced care planning part is on page 256.