AMDA Submits Comments on CURES 2.0 Legislation

December 19, 2019
Policy Snapshot

Last week the Society submitted comments to Reps. Diana DeGette (D-CO) and Fred Upton (R-MI), the co-sponsors of the CURES 2.0 plan. CURES 2.0 will aim to improve care delivery and look at how it is possible to modernize coverage and access to life-saving cures. The first installment of 21st Century CURES was signed into law nearly three years ago, and already there are better ways to prevent and screen cancer, an improved understanding of the human brain, and improvements in the field of regenerative medicine.

The Society noted that having monthly limits on telehealth services in the nursing facility setting stifles innovation and use of telehealth in the post-acute and long-term care (PALTC) setting, which is vital to the continuum of care and where many seriously and chronically ill Medicare and Medicaid beneficiaries receive care.

“We are also concerned about payment barriers that influence patient access in the PALTC setting that exist under the Medicare Merit-Based Payment System (MIPS) under the Quality Payment Program (QPP). Specifically, we request exemption from the penalties for failure to comply with the Promoting Interoperability (PI) category of MIPS. Current reporting requirements for the QPP PI category may unintentionally discourage eligible clinicians (ECs) from seeing patients in PALTC facilities,” the Society noted. The Society requested that a new CURES plans should exempt encounters in a skilled nursing facility (SNF) or NF  from a physician’s total number of services performed as well as exclude PALTC patients (POS 31 and 32) from the eligible patient pool for the purposes of ACI reporting.

The Society further noted that there should be incentives for EHR adoption and that sharing data between hospital and PALTC clinicians and nursing facilities should be more streamlined and harmonized for clinicians who practice in multiple settings including ambulatory, SNF, long-term acute care hospital, home health, and other settings in the post-acute care spectrum.

Click here to read the entire letter.