LeadingAge Comments on Proposed Physician Fee Schedule for CY2025

LeadingAge submitted comments to the Centers for Medicare and Medicaid Services (CMS) on September 9 about the proposed CY2025 Physician Fee Schedule.

Our letter supported CMS proposals relating to caregiver training services, including proposals to establish new coding for direct caregiver training services and individual behavior management caregiving training services, and proposals to include these new codes, along with certain other caregiver training codes, on the Medicare Telehealth List on a provisional basis. These policies reflect the critical role that informal caregivers play as part of the interdisciplinary teams that support older adults.

We also offered suggestions for additional flexibility in the delivery of Community Health Integration (person-centered planning, health system coordination, and facilitating access to community-based resources to address unmet social needs) and Principal Illness Navigation services (designed to help people with Medicare who are diagnosed with a serious, high-risk disease identify and connect with appropriate clinical and support resources), which CMS first established in 2024, to provide additional opportunities for aging services providers.

CMS also included proposals relating to the Medicare Shared Savings Program (MSSP). LeadingAge supported a proposal to expand access to pre-paid shared savings to existing Accountable Care Organizations and recommended a change relating to how such dollars could be used. We also offered comments relating to the MSSP for CMS' future consideration, with suggestions for how the model could evolve to further engage and create opportunities for aging services within this accountable care model.