The National Health Council appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ proposed rule revising payment policies under the Medicare Physician Fee Schedule (the Proposed Rule).
Founded in 1920, the NHC brings diverse organizations together to forge consensus and drive patient-centered health policy. The NHC provides a united voice for the more than 160 million people with chronic diseases and disabilities and their family caregivers. Made up of more than 125 diverse national health-related organizations and businesses, the NHC's core membership includes the nation’s leading patient advocacy organizations, which control its governance and policy-making process. Other members include health-related associations and nonprofit organizations including the provider, research and family caregiver communities; and businesses representing biopharmaceutical, device, diagnostic, generic, and payer organizations.
We support CMS’ proposed initiatives to refine the Quality Payment Program (QPP); enable appropriate payment for clinicians managing patients with one or more chronic condition; and expand coverage, coding, and payment mechanisms for opioid use disorder (OUD) treatment in opioid treatment programs (OTPs) and physician offices.
Our comments focus on ensuring that CMS’ policy refinements will facilitate, rather than impede, the ability of individuals with chronic conditions and their providers to design, implement, and continue treatment plans that align with the patient’s health care goals.