The American Academy of Family Physicians (AAFP) recently offered detailed recommendations and comments to the officials of HHS. The suggestions submitted by AAFP was regarding CMS’s advance policy of proposed policy and payment changes to the Medicare Advantage and prescription drug plans for next year.

In a letter, which was signed by AAFP Board Chair Wanda Filer reacted to certain proposals of the CMS that were related to three main issues such as network adequacy determinations, Medicare Part D formulary submissions, and quality measures.

Quality Measures

In an advance notice published by CMS, the agency discussed quality measures in health care for the next year. They also discussed the new and changing quality measures and revealed their plans on removing a few quality measures.

The officials from AAFP responded to this proposal by stating that the CMS should take adequate measures and better work to harmonize performance and quality measures. They also urged CMS to incorporate the use of Core Quality Measures Collaborative’s prime measure sets to do so. The AAFP added that doing so would “ensure parsimony, alignment, harmonization and the avoidance of competing quality measures among all payers.”

Formulary Submissions For Medicare Part D

The officials from CMS also confirmed that the 2018 formulary submission window would be open from May 15 to June 05, 2017. They added that the health care plans should meet the deadline for ensuring their formulary’s review. In addition to that, CMS also revealed their plans to implement safeguards in Part D plans that are related to opioid prescriptions and patient safety.

In their response, the AAFP advised all the affected parties including CMS to consult with the Academy’s policy on patient-centered formularies prior to implementing the newly proposed policies. In addition to that, the AAFP also cautioned CMS against decreasing the access to opioids for patients who are in need of powerful pain relievers.

Network Adequacy Determinations

CMS also wanted to have a submission of provider network information, which is specific to each Medicaid and Medicare plan by September 19, 2017. This was to make sure that all of these networks are capable of meeting the needs of the patient. However, the AAFP recommended CMS to give more responsibility to Medicare Advantage Organizations (MAOs) in order to ensure that provider directories are current and their networks are sufficient for meeting patient needs.

“If CMS moves forward with creating a nationwide Medicare Advantage provider database, the AAFP would like to reiterate its position that physicians play a key part, but MAOs should provide the bulk of the information,” AAFP said. “Network information should be aggregated directly from the MAOs’ accurate and up-to-date provider directories. Physicians should not be expected to go to another website to update the nationwide provider database.”

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