In its proposed 2016 physician fee schedule rule published on
July 15 (the "Rule"), the Centers for Medicare &
Medicaid Services (CMS) proposed new separate Medicare payment for
two CPT codes (99497 and 99498) that describe advance care planning
(ACP) services. (See page 41773 of the Rule.) However, the
proposal falls short of creating a clear coverage policy.
The Rule specifically states that paying for the two new codes
"does not mean that Medicare has made a national coverage
determination regarding the service." In fact, CMS reiterated
that the ACP CPT codes "should be reported when the
described service is reasonable and necessary for the diagnosis or
treatment of illness or injury." Additionally, the example
provided in the Rule includes ACP services that are provided in
conjunction with a visit for treatment of an existing medical
condition; however, CMS did note that the two services could be
provided on different days.
CMS requested input on when payment for ACP would be appropriate in
other circumstances. While roughly one-quarter of Medicare's
annual spending is on care provided in the last year of a
beneficiary's life (see "10 FAQs: Medicare's Role in End-of-Life
Care," recently published by the Kaiser Family
Foundation), CMS continues to struggle with developing a cogent
national policy on payment for end-of-life discussions. Not
only would a reasonable Medicare policy reduce costs by
avoiding undesired care, more importantly, it would help healthcare
providers better understand the desires of patients facing
end-of-life care decisions.
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