Each year the Centers for Medicare and Medicaid Services (CMS) reviews payment practices and policy changes under fee-for-service, or traditional, Medicare. The CY2024 PFS included important coding and payment changes for services to address health-related social needs (HRSNs) through separate payments for Community Health Integration (CHI), SDOH Risk Assessment, and Principal Illness Navigation (PIN) services.

In July 2024, CMS released its annual draft proposed updates for next year’s rules (CY2025 Medicare Physician Fee Schedule), which includes a request for information (RFI) regarding barriers to implementation for services to address HRSNs. 

The draft rule also includes proposed updates to:

• Caregiver Training Services;
• ACO quality measures re: screening for HRSNs; and
• the Advanced Primary Care Model (APCM)

All of these proposed changes could affect services to address HRSNs. 

On September 9, 20204 the Partnership submitted two letters to CMS on behalf of Partnership Co-Chairs and undersigned organizations. Sixty-five organizations signed on to the response to the request for information (RFI) regarding current barriers to implementing services to address HRSNs (CHI/PIN). Fifty-three organizations signed on to the letter regarding changes needed and proposed updates for telehealth, caregiver training services, ACO quality measures, and the Advanced Primary Care Model. Agency officials will review and document the more than 12,000 comments submitted as they finalize the rule.

Stay tuned for updates once we see the final rule published—likely in early November 2024. We will also be in touch with stakeholders regarding implementation resources that we plan to create and promote
once we see the final rule.

Each year the Centers for Medicare and Medicaid Services (CMS) reviews payment practices and policy changes under fee-for-service, or traditional, Medicare. The CY2024 PFS included important coding and payment changes for services to address health-related social needs (HRSNs) through separate payments for Community Health Integration (CHI), SDOH Risk Assessment, and Principal Illness Navigation (PIN) services.

In July 2024, CMS released its annual draft proposed updates for next year’s rules (CY2025 Medicare Physician Fee Schedule), which includes a request for information (RFI) regarding barriers to implementation for services to address HRSNs. 

The draft rule also includes proposed updates to:

• Caregiver Training Services;
• ACO quality measures re: screening for HRSNs; and
• the Advanced Primary Care Model (APCM)

All of these proposed changes could affect services to address HRSNs. 

SIGN-ON REQUEST:
Please consider joining the Partnership to Align Social Care Co-Chairs and other organizational stakeholders on TWO sign-on letters offering comments. You may sign on to one or both letters: 

1. Sign-on letter responding to the RFI re: barriers to implementing services to address HRSNs
2. Sign-on letter responding changes needed and proposed updates for telehealth, caregiver training services, ACO quality measures, and the Advanced Primary Care Model

We also encourage you to download template language covering all of these issues and incorporate as applicable into your organization's response . As a reminder, comments are due by 5:00 p.m. ET on September 9, 2024, and can be submitted online.  

RESOURCES:

• SIGN-ON Letters (combined) responding to CMS CY2025 PFS Proposed Rule (pdf)
• Template language provided by the Partnership (Word version available for download)
• CMS CY2025 PFS Proposed Rule: https://www.regulations.gov/document/CMS-2024-0256-0045 
• Additional information and resources from the Partnership about this proposed rule: https://www.partnership2asc.org/implementation-resources/ and Resources List

Members of the Convergence Collaborative on Social Factors of Health agreed that improving collaboration across social and health sectors—and between private and public organizations—is essential for effective SDOH strategies. Read the Collaborative’s latest Blueprint for Action consensus solutions to learn why achieving the necessary level of collaboration requires improving system integration: https://convergencepolicy.org/wp-content/uploads/2024/07/Social-Factors-of-Health-Blueprint-for-Action.pdf

This session focused on what to expect from negotiations with a health plan when developing a contracted partnership. Nikki Kmicinski, Executive Director at Western New York Integrated Care Collaborative, Inc., shared her experiences in negotiating with healthcare organizations and discussed strategies to achieve a mutually beneficial contract for both parties. Attendees also had the opportunity to break into moderated group discussions with their peers.

Link to Recording

Meeting slides (PDF)

Meeting Summary and Notes