The Society of Nuclear Medicine and Molecular Imaging (SNMMI) is concerned that the proposed care transitions code is not well-defined enough to meet the goals of the program. "There is nothing to limit the billing of the code to only those clinicians providing comprehensive primary care…the code could be billed by any physician…with only limited or no prior contact with the beneficiary. Because the proposed rule does not require a face-to-face visit, beneficiaries may not be aware that a clinician is billing for coordinating their care."
Kaiser Permanente, a California-based integrated delivery system, also supports care coordination but opposes the requirement that the coordinating physician must have seen a patient 30 days before a hospitalization. "Large multi-specialty medical groups provide team-based care. Patients have a designated primary care physician, but they may be seen by other members of the care team or specialists before and after the hospitalization."
As part of healthcare reform, CMS is directed to periodically identify and review the fees paid for services to assess if increased use or new technologies may have affected the value of those services. For 2013 CMS proposed the review of evaluation and management service furnished as part of global surgical services.
In its comment letter, the American Academy of Family Physicians (AAFP) said it has "long argued" that global surgical packages are inflated in terms of "the number and level of post-operative visits" assumed to be included in the value of the codes.
MedPac, the independent Congressional agency established to advise Congress on issues affecting the Medicare program, expressed concern about the pace of validating the fee schedule's estimates of the time providers spend furnishing services.
MedPac noted that the estimates rely "on surveys conducted by physician specialty societies," which have a stake in the process. The commission suggests that CMS establish time estimates with data collected from physicians' offices and other settings where physicians and other healthcare professionals provide care.