AMDA Opposed to Cuts to SNF Visits in Proposed CY2021 Physician Fee Schedule – Will be Catastrophic to PALTC Practices and Cause Severe Shortage in Access to Care for America’s Seniors

August 13, 2020
Policy Snapshot

One of the unpleasant surprises in the release of the CY2021 Physician Fee Scheduled Proposed Rule earlier this month was an included 8-10% cut to the SNF family of CPT codes. The cuts occurred due to a decrease in the conversion factor that is part of the formula that determines reimbursement for the codes. The redistribution of pay under the physician fee schedule is a result of the budget neutrality requirements linked to the 2020 rule’s increase in pay for evaluation and management (E&M) office visits starting in 2021. The Centers for Medicare & Medicaid Services (CMS) says in a press release that the higher pay rates take into account “the changes in the practice of medicine, recognizing that additional resources are required of clinicians to take care of the Medicare patients, of which two-thirds have multiple chronic conditions.”

View the cuts in payment.

Regardless of the math of this recalculation, cutting the SNF family of services makes very little sense, especially during the time of COVID-19, for the following reasons:

  • CMS has repeatedly announced significant support for nursing homes and the residents they serve in the era of COVID-19. Penalizing practitioners who have been at the front line of potential harm, caring for the most seriously affected, is entirely contradictory to this publicly stated position.
  • An approximately 8-10% reduction in payment would cause substantial shortages of nursing facility practitioner services. Many practitioners work in both an office and nursing home setting, and such a reduction would cause individuals to decrease presence in the nursing home in favor of the office setting for economic reasons.
  • The estimated reduction would cause severe economic effects in those practitioners who provide dedicated services to this site. Few younger practitioners would enter this field, and many older ones would likely retire, which would challenge service provision in many areas of the country.
  • This is the time when clinical leadership in nursing facilities is paramount to ensuring the safety of residents. These cuts will exacerbate an already challenged area of medicine for quality trained PALTC practitioners
  • Rural areas are likely to be the most affected with regards to shortages of practitioner services, which is also contradictory to the recently announced goal of enhancing Medicare services to rural areas.

Back in July, the Society signed onto a broad stakeholder letter asking the administration to suspend budget neutrality that would provide more flexibility to increase payment to office and other E&M services without having to cut payment for other specialties. During the COVID crisis, it is critical that the physician practices remain viable so that Americans can continue to receive the care they need. This is even more crucial to the vulnerable seniors in nursing facilities.

The Society is currently developing formal comments on all provisions included in the proposed rule. While official comments will be submitted prior to the October 4 deadline, the Society strongly urges the administration to not follow through with the proposed cuts.