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

This month’s Gravity Implementation Affinity Group featured Timothy McNeill, RN, MPH from the Partnership to discuss the new calendar year 2024 social needs HCPCS codes. Implementers learned how Gravity SNOMED-CT intervention codes align with and support additional documentation aligned with regulatory and policy drivers.

Thank you to Civitas Networks for Health for your support of the Gravity Implementation Affinity Group meetings.

Our Partnership to Align Social Care co-chair, Timothy McNeill, RN, MPH, spoke at USAging's Aging Policy Briefing with colleagues from around the nation about the 2024 Medicare Physician Fee Schedule and how to implement changes in billing codes to better align care between CBOs, health entities, and Area Agencies on Aging.

Tim was joined by Kelly Cronin, Deputy Administrator, Center for Innovation and Partnership, U.S. Administration for Community Living; Doug Jacobs, MD, MPH, Chief Transformation Officer, Center for Medicare & Medicaid Services; and Christine Vanlandingham, CEO, Region IV AAA in St. Joseph Michigan.

We encourage you to learn more about these changes in the Medicare Physician Fee Schedule here: https://go.cms.gov/4c5f090

A recently released Health Affairs article, Improving Health And Well-Being Through Community Care Hubs, authored by a cohort of federal agency employees, details the importance of developing, supporting, and investing in multistakeholder collaborations to address social drivers of health. In particular, the authors point to the Partnership to Align Social Care, a national learning and action network, and its role to convene leaders across CBOs, health plans and systems, national associations, philanthropy, and federal agencies to co-design a multifaceted strategy to enable successful partnerships among health care organizations and hubs. Read the blog and more resources about Community Care Hubs at www.partnership2asc.org/cch-resources.