A National Academies of Sciences, Engineering, and Medicine committee will develop a written response to questions for public input included in Centers for Medicare & Medicaid Services’ (CMS)“CY 2025 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies” Proposed Rule.
The committee will produce a report with recommendations in response to the following questions from the proposed rule:

• Does the proposed Advanced Primary Care Management (APCM) payment policy reflect CMS’ efforts to recognize the delivery of advanced primary care?
• Do the proposed elements and requirements appropriately reflect the care management services for advanced primary care and are the service descriptions accurate?
• Is the Qualified Medicare Beneficiary status an appropriate indicator to identify beneficiaries with added social risk, and what is an equivalent marker of social deprivation for use in commercial markets?
• What is a low burden way for practitioners to meet APCM billing requirements?
• What is the best approach to effectively educate both practitioners and beneficiaries on the benefits of APCM, especially as it reflects a new bundle of services that may have previously been separately billed?
• How can CMS better support primary care clinicians and practices who may be new to population-based and longitudinal care management?
• Should CMS evolve the proposed APCM services into an advanced primary care payment that includes evaluation and management (E/M) and other relevant services, or maintain a separate code set for APCM?
• If evaluation and management E/M services are bundled together for advanced primary care payments, how can CMS ensure that there is not a disincentive for primary care clinicians to continue to provide E/M visits, or increase accountability to E/M visits as warranted?
• As many codes depend on E/M visits (for example, as the base code for an add-on code, or to initiate specific care management activities), how should CMS consider the downstream impacts of incorporating E/M visits into advanced primary care payments?
• Should CMS consider incorporating other communication technology based services into advanced primary care hybrid payments, such as Remote Physiologic Monitoring and/or Remote Therapeutic Monitoring?
• CMS has historically used information presented by the Relative Value Scale Update Committee to determine physician fee schedule (PFS) payment rates. Are there other sources of data on the relative value of primary care services that CMS should consider when setting hybrid payment rates?
• How can CMS reduce the potential burden of billing for population-based and longitudinal care services?
• Should CMS attribute the advanced primary care clinical episode to a single clinician, or consider weighted attribution and payment for multiple entities or clinicians? How could weighted attribution and payment work? What rules or processes should CMS consider to attribute the episode?
• Care management coding and payment have historically required an initiating visit prior to starting monthly billing, to ensure that the services are medically reasonable and necessary and consistent with the plan of care. Are there other ways that CMS could ensure the clinician billing APCM is responsible for the primary care of the Medicare beneficiary?
• Care management coding and payment require beneficiary cost sharing. Has beneficiary cost sharing been a barrier to practitioners providing such services?
• How can CMS structure advanced primary care hybrid payments to improve patient experience and outcomes?
• What activities that support the delivery of care that is coordinated across clinicians, support systems, and time should be considered for payment in an advanced primary care bundle that are not currently captured in the PFS?
• How can CMS structure advanced primary care hybrid payments to ensure appropriate access to telephonic and messaging primary care services?
• What risk factors, including clinical or social, should be considered in developing payment for advanced primary care services?
• What risk adjustments should be made to proposed payments to account for higher costs of traditionally underserved populations?
• What metrics should be used or monitored to adjust payment to ensure that health disparities are not worsened as an unintended consequence?
• What should CMS consider so that that advanced primary care bundles could be used to promote accountable care across payers, both commercial and Medicaid?
• What are key patient-centered measures of quality, outcomes and experience that would help ensure that hybrid payment enhances outcome and experience for patients?