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.