The CY2024 Physician Fee Schedule Final Rule, effective January 1, 2024, includes significant policy changes for Medicare payments under the PFS and other Medicare Part B payment policy issues. The rule includes significant coding and payment changes for services to address HRSNs including Community Health Integration (CHI), Social Determinants of Health (SDOH) Risk Assessment, and Principal Illness Navigation (PIN) services.
There are also provisions to support Medicare providers contracting with community care hubs (CCHs) and community-based organizations (CBOs) to address HRSNs for priority populations. These codes are the first that are specifically designed to describe services involving community health workers, care navigators, and peer support specialists, and that allow these services to be provided by personnel employed by CCHs/CBOs under the general supervision of the billing practitioner.
The Partnership and Freedmen’s Health Consulting are collaborating to develop a series of resources to help stakeholders implement these billing codes. More information about those resources is below including a recording of a webinar event to discuss the recently released report, Understanding the Medicare Physician Fee Schedule Billing Codes for: Community Health Integration (CHI), Principal Illness Navigation (PIN), and Principal Illness Navigation – Peer Support (PIN-PS) Services.
Policy updates were also proposed in the CY2025 Medicare Physician Fee Schedule. The Partnership hosted a webinar detailing what the proposed rule would mean for HRSNs and two stakeholder calls to discuss these important potential policy updates, and sent two sign-on letters to CMS in response to the proposed rule.
Partnership to Align Social Care Resources:
- CY 2025 Physician Fee Schedule
- Letter responding to the CMS request for information regarding barriers to implementing codes to address HRSNs (pdf)
- Letter responding to updates needed and proposed changes to telehealth flexibilities, Caregiver Training Services (CTS), ACO quality measures re: HRSN screening; and the Advanced Primary Care Model (APCM) (pdf)
- Template language for stakeholders to consider incorporating into organizational/individual comments on the proposed rule (Word doc for download)
- September 4, 2024 recording discussing sign-on requests and letter components
- Stakeholder Calls, August 2024
- August 6 Recording and Slides (pdf). Discussion included a brief review of the CY2024 PFS Final Rule re: HRSNs codes, an overview of the CY2025 PFS Proposed Rule request for information re: CHI/PIN codes, and addressed FAQs.
- August 14 Recording and Slides (pdf). Discussion included an overview of submission guidelines, potential responses to the RFI re: CHI/PIN codes, the Advanced Primary Care Model RFI, and Q&A. Other resources discussed include Aging and Disability Business Institute guides to Insurance in Contracting, Becoming a Medicare Provider, and Model Contracts for CBO Networks (including CCHs)
- Webinar: What Does the CY 2025 Medicare Physician Fee Schedule Proposed Rule Mean for Addressing HRSNs?, July 30, 2024
- Webinar Recording
- Slides (pdf)
- Resources List (pdf)
- Understanding the Medicare Physician Fee Schedule Billing Codes for: Community Health Integration (CHI), Principal Illness Navigation (PIN), and Principal Illness Navigation – Peer Support (PIN-PS) Services–A Primer (pdf)
- Webinar: Community Health Integration and Principal Illness Navigation Medicare Codes, April 3, 2024
- Webinar Recording
- Slides (pdf)
- Webinar: The Medicare Physician Fee Schedule (PFS) Includes Codes to Address HRSNs…What Happens Next?, November 15, 2023
- Webinar Recording
- Slides (pdf)
Freedmen’s Health Consulting Resources:
- Pathways to Payment: https://communityhealthintegration.info/
Administration Resources:
- (NEW): Proposed Rule, CY2025 Medicare Physician Fee Schedule: https://www.regulations.gov/document/CMS-2024-0256-0045
- CMS FAQ re: Health Related Social Needs: https://www.cms.gov/files/document/health-related-social-needs-faq.pdf
- CMS Medicare Learning Network Booklet, Health Equity Services in the 2024 Physician Fee Schedule Final Rule
- Link to Final Rule: https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other
- CMS PFS Final Rule Fact Sheet: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule
- Press Release Detailing Efforts to Advance Health Equity: https://www.cms.gov/newsroom/press-releases/cms-finalizes-physician-payment-rule-advances-health-equity
- Press Release Detailing Behavioral Health Care Provisions: https://www.cms.gov/newsroom/press-releases/cms-makes-hospital-prices-more-transparent-and-expands-access-behavioral-health-care