Statement of Rick Kellerman, M.D., President, American Academy of Family Physicians, Shawnee Mission, KS Testimony Before the Subcommittee on Health of the House Committee on Ways and Means May 10, 2007
Chairman Stark, and members of the subcommittee, I
am Dr. Rick Kellerman of Wichita, Kansas, and I am president of the American
Academy of Family Physicians representing 93,800 members nationwide. On
behalf of the Academy, thank you for this opportunity to share with the
subcommittee the proposals that AAFP believes to be important elements of
physician payment reform under Medicare.
The AAFP appreciates the work this subcommittee has undertaken to examine how
Medicare pays for services physicians deliver to Medicare beneficiaries and we
share the subcommittee’s concerns that the current system is inefficient,
inaccurate and outdated. Finding a more efficient and effective method of
reimbursing physicians for services delivered to Medicare beneficiaries with a
large variety of health conditions is a necessary but difficult endeavor, and
one that has tremendous implications for millions of patients and for the
Medicare program itself.
We
particularly appreciate your asking us to discuss what we are calling the
Patient-Centered Medical Home as a component of a Medicare program that offers
better health care more efficiently. Family physicians believe that the
restructuring of Medicare payment should be done with the needs of Medicare
patients foremost in mind. Since most of these patients have two or more
chronic conditions that call for continuous management and that depend on
differing pharmaceutical treatments, Medicare should focus on how physicians
integrate the health care these patients receive from different providers and
settings, with the goal of preventing duplicative tests and procedures and
assuring the availability to each provider of the most accurate and complete
information regarding each patient. We do not believe that the Patient
Centered Medical Home is business as usual, but rather a significant step
toward added value for the patient, for the complex array of health care
providers and for the Medicare program.
Current Payment Environment The environment in which
U.S. physicians practice and are paid is challenging at best. Medicare has
a history of making disproportionately low payments to family physicians,
largely because its payment formula is based on a reimbursement scheme that
rewards procedural volume and fails to foster comprehensive, coordinated
management of patients. This formula has produced payment rates that have
declined, except for Congressional intervention, by 5-7 percent annually for
the last five years. As a result, the Medicare payment rate for physicians has
fallen to the 2001 level. These steep annual cuts resulting from the flawed
payment formula serve to undermine confidence in the Medicare program. In
this current environment, physicians know that, without annual Congressional
action, they will face a 10-percent cut in the Medicare payment rate for 2008
and cuts in the 5-percent range annually thereafter. Clearly, the Sustainable
Growth Rate (SGR) formula belies its name and simply is not sustainable.
Primary Care Physicians in the U.S.
This persistent payment imbalance has led to a decline in the
numbers of graduates from US medical schools choosing primary care medicine.
As a result, while other developed countries have a better balance of primary
care doctors and subspecialists, primary care physicians make up less than
one-third of the U.S. physician workforce. Compared to those in other
developed countries, Americans spend the highest amount per capita on
healthcare but have some of the worst healthcare outcomes.
However, more than 20 years of evidence shows that having a health
care system based on primary care benefits the economy and the patients’
health. Three years ago, a study comparing the health and economic outcomes of
the physician workforce in the U.S. reached this conclusion (Health Affairs,
April 2004). By using a system of health care that is not predicated on
primary care physicians coordinating patients’ care, we
the U.S. health care system pays a steep economic price and our Medicare
beneficiaries pay a steeper one in terms of their quality of life.
The businesses that purchase health insurance for their employees
are recognizing the value of a health care system based on primary care. For
example, Martin-Jose Sepúlveda, MD, who is the Vice President for Global
Well-being Services and Health Benefits for IMB, Corp., recently wrote “Why
should major companies support patient-centered primary care? Because research
shows that patient-centered primary care results in better health care, lower
costs, greater satisfaction with the health-care system and more equal access
to health care for all citizens.”
A Chronic Care Model in Medicare If we do not change the Medicare payment
system, the aging population and the rising incidence of chronic disease will
overwhelm Medicare’s ability to provide health care. Currently, 82 percent of
the Medicare population has at least one chronic condition and two-thirds have
more than one illness. However, the 20 percent of beneficiaries with five or
more chronic conditions account for two-thirds of all Medicare spending.
There is strong evidence the Chronic Care Model (Ed Wagner,
Robert Wood Johnson Foundation) would improve health care quality and
cost-effectiveness, integrate patient care, and increase patient satisfaction.
This well-known model is based on the fact that most health care for the
chronically ill takes place in primary care settings, such as the offices of
family physicians. The model focuses on six components:
- self-management by patients of their disease
- an organized and sophisticated delivery system
- strong support by the sponsoring organization
- evidence-based support for clinical decisions
- information systems; and
- links to community organizations.
This model, with its emphasis on care-coordination, has been
tested in some 39 studies and has repeatedly shown its value. While we believe
reimbursement should be provided to any physician who agrees to coordinate a
patient’s care (and serve as a medical home), generally this will be provided
by a primary care doctor, such as a family physician. According to the Institute of Medicine, primary care is “the provision of integrated, accessible health care
services by clinicians who are accountable for addressing a large majority of
personal health care needs, developing a sustained partnership with patients,
and practicing in the context of family and community.” Family physicians are
trained specifically to provide exactly this sort of coordinated health care to
their patients.
The AAFP advocates for a new Medicare physician payment system
that embraces the following:
- Adoption of the “Medical Home” model which would
provide a per month care management fee for physicians whom beneficiaries
designate as their “Patient-centered Medical Home;”
- Continued use of the resource-based relative
value scale (RBRVS) using a conversion factor updated annually by the
Medicare Economic Index (MEI);
- No geographic adjustment in Medicare allowances
except as it relates to identified shortage areas;
- A phased-in voluntary pay-for-reporting, then
pay-for-performance system consistent with the IOM recommendations.
Care Coordination and a Patient-Centered Medical Home From the outset, the
Medicare program has based physician payment on a fee-for-service system. As a
result, Medicare currently is a system of misaligned incentives which rewards
individual physicians for ordering more tests and performing more procedures.
The system provides no incentive for physicians to coordinate the tests, procedures,
or patient health care generally and it puts very little emphasis on preventive
services and health maintenance. This payment method has produced an expensive,
fragmented Medicare program.
To correct these inverted incentives, the AAFP recommends that
beginning in 2008, Medicare compensate physicians for care coordination
services The Institute
of Medicine (IOM)
has repeatedly praised the value of, and cited the need for, care coordination
as has the Medicare Payment Advisory Commission (MedPAC). And while there are a
number of possible methods to build this into the Medicare program, AAFP
recommends a blended model that combines fee-for-service with a
per-beneficiary, per-month stipend for care coordination in addition to
meaningful incentives for delivery of high-quality and effective services in
the Patient-Centered Medical Home.
The patient-centered, physician-guided medical home is being
advanced jointly by the AAAFP, the American Academy of Pediatrics (AAP), the American College of Physicians (ACP) and the American Osteopathic Association (AOA). This
model would include the following elements:
- Personal physician - each patient has an ongoing relationship with
a personal physician trained to provide first contact, continuous and
comprehensive care.
- Physician directed medical practice
– the personal physician leads a team of
individuals at the practice level who collectively take responsibility for
the ongoing care of patients.
- Whole person orientation – the personal physician is responsible for
providing for all the patient’s health care needs or taking responsibility
for appropriately arranging care with other qualified professionals. This
includes care for all stages of life; acute care; chronic care; preventive
services; and end of life care.
- Care is coordinated and/or integrated
across all providers and settings of the health
care system (e.g., subspecialty care, hospitals, home health agencies,
nursing homes) and the patient’s community (e.g., family, public and
private community-based services) facilitated by registries, information
technology, health information exchange and other means to assure that
patients get the indicated care when and where they need and want it in a
culturally and linguistically appropriate manner.
- Quality and safety are hallmarks of the patient-centered medical
home.
Evidence-based medicine and clinical
decision-support tools guide decision making. Physicians in the practice
accept accountability for continuous quality improvement through voluntary
engagement in performance measurement and improvement. Patients actively
participate in decision-making and feedback is sought to ensure patients’
expectations are being met.
Information technology is utilized
appropriately to support optimal patient care, performance measurement, patient
education, and enhanced communication.
Practices go through a voluntary
recognition process by an appropriate non-governmental entity to demonstrate
that they have the capabilities to provide patient-centered services consistent
with the medical home model. To this end, the AAFP, AAFP, ACP and AOA are in
discussions with the National Committee for Quality Assurance (NCQA) on
creating such a recognition program for the Patient-Centered Medical Home.
- Enhanced access to care through systems such as
open
scheduling, expanded hours and new options for communication between
patients, their personal physician, and office staff.
A reimbursement system with appropriate incentives for the patient
and the physician recognizes the time and effort involved in ongoing care
management.
The AAFP commends the Congress for incorporating the medical home demonstration
into the Medicare physician payment provisions of the Tax Reform and Health
Act. However, the statutory composition of the provision including the
requirement of the development of a procedural code and establishing a value
for same, will unduly delay the implementation of the medical home. Code
development and valuation alone can take two plus years. Thus the results from
a three-year demonstration will not be available until well beyond 2011. Because
of the strength of the existing literature describing the effectiveness (both
health and economic) of the medical home, AAFP would urge the committee to authorize
the Centers for Medicare and Medicaid Services (CMS) to adopt the Patient-centered Medical Home as an interim
component of physician payment while awaiting the implementation of and results
from the demonstration project.
Payment of the care management fee for the medical home would
reflect the value of physician and non-physician staff work that falls outside
of the face-to-face visit associated with patient-centered care management, and
it would pay for services associated with coordination of care both within a given
practice and between consultants, ancillary providers, and community resources.
Patient-Centered Medical Home: A Gateway, not a “Gatekeeper”
It
is important to note that the patient-centered Medical Home differs from the
so-called "gatekeeper” model employed in the ‘80s and ‘90s. The PC-MH
model expands access rather than decreases it as a capitated gatekeeper model could.
The PC-MH model does not interfere with patient choice or patient self-referral
but it offers appropriate incentives for physicians and patients to use
resources more appropriately. The Academy believes this is what patients want
and need and the mechanism that can improve quality of care and quality of life
for beneficiaries and increase cost-effectiveness for the Medicare program.
In
fact, patients and payers alike want a medical “network administrator” for
their employees, beneficiaries and patients. AAFP, AAP, ACP and AOA have also conferred
with major employers, like IBM, in determining what these employers envision as
an appropriate medical home for their employees. The primary care physician
organizations have been working with IBM in Austin, Texas, to create a
demonstration project for their employees that will examine the characteristics
of a successful patient-centered medical home. And AAFP, ACP, AOA and the
National Association of Community Health Centers have joined with the ERISA
Industry Committee, the National Business Group on Health and several major employers
to form the Patient Centered Primary Care Collaborative to advance the medical
home as a way to improve the health care system generally.
The Cost-Effectiveness of the Medical Home
We understand the very difficult budget constraints that Congress
faces as you try to determine how to improve Medicare. The restructuring of
payment that we are suggesting will include an additional investment in the
short term. But there is ample evidence already that the potential savings are
large and near-term. Community Care of North Carolina (CCNC) is a state-wide
health care delivery program developed by Allan Dobson, MD, Assistant Secretary
for the North Carolina Department of Health and Human Services. The program
provides a primary care medical home for all the Medicaid recipients in the
state. It joins health care providers, like hospitals and nursing homes, and
necessary social service providers, like substance abuse and mental health
services, with the local physicians. The system pays the physician practice an
additional per-patient, per-month fee to coordinate the care of the Medicaid
patients, while also paying a regional network administrator, who makes sure
the necessary technical and ancillary services (like transportation, health
education counselors and trained translators) are available within the region.
The state legislature has received a report from an independent
audit by Mercer that showed from July 1, 2003 to June 30, 2004 the state spent $10.2 million on the CCNC program, but saved $124 million compared to the
previous fiscal year and $225 million if the same population was served by the
fee-for-service only system. The conclusion is that for every Medicaid dollar
spent on the medical home in North Carolina, the state is saving $8. We
realize that the Congressional Budget Office is reluctant to include savings in
how it calculates the cost of a program, but a realistic view of what Medicare
patients need shows that a medical home will provide them their health care at
less cost to them and to the system. Somehow, CBO should take that into
account.
Information Technology in the Medical Office Setting
An effective system emphasizing coordinated care is predicated on
the presence of health information technology, i.e., the electronic health
record (EHR) in the physician’s office. Using advances in health information technology
(HIT) also aids in reducing errors and allows for ongoing care assessment and
quality improvement in the practice setting – two additional goals of recent
IOM reports,. We have learned from the
experience of the Integrated Healthcare Association (IHA) in California that
when physicians and practices invested in EHRs and other electronic tools to
automate data reporting, they were both more efficient and more effective,
achieving improved quality results at a more rapid pace than those that lacked
advanced HIT capacity.
Family
physicians are leading the transition to EHR systems in large part due to the
efforts of AAFP’s Center for Health Information Technology (CHiT). The AAFP
created the CHiT in 2003 to increase the availability and use of low-cost,
standards-based information technology among family physicians with the goal of
improving the quality and safety of medical care and increasing the efficiency
of medical practice. Since 2003, the rate of EHR adoption among AAFP members
has more than doubled, with over 30 percent of our family physician members now
utilizing these systems in their practices.
In
an HHS-supported EHR Pilot Project conducted by the AAFP, we learned that
practices with a well-defined implementation plan and analysis of workflow and
processes had greater success in implementing an EHR. CHiT used this
information to develop a practice assessment tool on its Web site, allowing
physicians to assess their readiness for EHRs.
In
any discussion of increasing utilization of an EHR system, there are a number
of barriers, and cost is a top concern for family physicians. The AAFP has
worked aggressively with the vendor community through our Partners for Patients
Program to lower the prices of appropriate information technology. The AAFP’s
Executive Vice President serves on the American Health Information Community
(AHIC), which is working to increase confidence in these systems by developing
recommendations on interoperability. The AAFP sponsored the development of the
Continuity of Care Record (CCR) standard, now successfully balloted through the
American Society for Testing and Materials (ASTM). We initiated the Physician
EHR Coalition, now jointly chaired by ACP and AAFP, to engage a broad base of
medical specialties to advance EHR adoption in small and medium size ambulatory
care practices. In preparation for greater adoption of EHR systems, every
family medicine residency will implement EHRs by the end of this year.
To
facilitate accelerate care coordination, the
AAFP joins the IOM in encouraging federal funding for health care providers to
purchase HIT systems. According to the US Department of Health & Human
Services, billions of dollars will be saved each year with the wide-spread
adoption of HIT systems. While the federal government has already made a
financial commitment to this technology, only a few
dollars trickle down to wherethe funding, unfortunately, is not directed
to these systems that will truly have the
most impact and where ultimately all health care is practiced - at the
individual patient level. We encourage you to include funding in the form of
grants, low interest loans or tax credits for those physicians committed to
integrating an HIT system in their practice.
Measures of quality and efficiency sh ould include a
mix of outcome, process and structural measures. Clinical care measures
must be evidence-based. Physicians should be directly involved in determining
the measures used for assessing their performance.
Aligning Incentives In replacing the outdated and dysfunctional
SGR formula, Congress should look to a method of determining physician
reimbursement that is sensitive to the costs of providing care, creates a
stable and predictable economic environment, and aligns the incentives to
encourage evidence-based practice and foster the delivery of services that are
known to be more effective and result in better health outcomes for patients. Just
as importantly, the reformed system should facilitate efficient use of Medicare
resources by paying for appropriate utilization of effective services and not
paying for services that are unnecessary, redundant or known to be ineffective.
Such an approach is endorsed by the IOM in its 2001 publication Crossing the
Quality Chasm.
Another IOM
report released
in autumn of 2006 entitled Rewarding Provider Performance: Aligning
Incentives in Medicare states that aligning payment incentives with quality
improvement goals represents a promising opportunity to encourage higher levels
of quality and provide better value for all Americans. The objective of aligning
incentives through pay-for-performance is to create payment incentives that
will: (1) encourage the most rapidly feasible performance improvement by all
providers; (2) support innovation and constructive change throughout the health
care system; and (3) promote better outcomes of care, especially through
coordination of care across provider settings and time. The Academy concurs
with the IOM recommendations that state:
- Measures
should allow for shared accountability and more coordinated care across
provider settings.
- P4P
programs should reward care that is patient-centered and efficient. And they
should reward providers who improve performance as well as those who
achieve high performance.
- Providers
should be offered (adequate) incentives to report performance measures.
- Because
electronic health information technology will increase the probability of
a successful pay-for-performance program, the Secretary should explore
ways to assist providers in implementing electronic data collection and
reporting to strengthen the use of consistent performance measures.
Aligning the incentives requires collecting and reporting data
through the use of meaningful quality measures. AAFP is supportive of
collecting and reporting quality measures and has demonstrated leadership in
the physician community in the development of such measures. It is the
Academy’s belief that measures of quality and efficiency should include a mix
of outcome, process and structural measures. Clinical care measures must
be evidence-based and physicians should be directly involved in determining the
measures used for assessing their performance.
Quality Reporting
AAFP is supportive of collecting and reporting quality measures
and has led the physician community in the development of meaningful measures.
Consistent with the philosophy of aligning incentives, the reward for
collecting and reporting data must be commensurate with the effort and
processes necessary to comply and must be sufficient to obtain the desired
response from providers. The Academy is skeptical that the incentive of 1.5
percent of a physician’s covered charges for collecting and reporting quality measurement
data will be sufficient to cover the actual cost of operationalizing such a program.
However, we are generally and conceptually supportive of the policy and will
monitor its implementation closely.
A Framework for Pay-for-performance The following is a
proposed framework for phasing in a Medicare pay-for-performance program for
physicians that is designed to improve the quality and safety of medical care
for patients and to increase the efficiency of medical practice.
- Phase 1
All physicians would receive a
positive update in 2008, consistent with recommendations of MedPAC. Congress
should establish a floor for such updates in subsequent years.
- Phase 2
Following the implementation of
the Physician Quality Reporting Initiative, Medicare would encourage
structural and system changes in practice, such as electronic health
records and registries, through a “pay for reporting” incentive system
such that physicians could improve their capacity to deliver quality
care. The update floor would apply to all physicians.
- Phase 3
Pay-for-reporting transitions
to pay-for performance and particular effort is made to ensure that the
quality bonus is sufficient to cover the costs of administration as well
as providing sufficient incentive to participate. Medicare continues to encourage reporting of data
on evidence-based performance measures that have been appropriately vetted
through mechanisms such as the National Quality Forum and the Ambulatory
Care Quality Alliance. The update floor would apply to all
physicians.
- Phase 4
Contingent on repeal of the SGR
formula and development of a long term solution allowing for annual
payment updates linked to inflation, Medicare would encourage continuous
improvement in the quality of care through incentive payments to
physicians for demonstrated improvements in outcomes and processes, using
evidence-based measures.
This
type of phased-in approach is crucial for appropriate implementation.
While there is general agreement that initial incentives should foster
structural and system improvements in practice, decisions about such structural
measures, their reporting, patient registries, threshold for rewards, etc.,
remain to be determined.
The
program must provide incentives – not punishment – to encourage continuous
quality improvement. For example, physicians are being asked to bear the
costs of acquiring, using and maintaining health information technology in
their offices, with benefits accruing across the health care system – to
patients, payers and insurance plans. Appropriate incentives must be
explicitly integrated into a Medicare pay-for-performance program if we are to
achieve the level of infrastructure at the medical practice to support
collection and reporting of data.
Conclusion
It is time to stabilize and modernize Medicare by recognizing the
importance of, and appropriately valuing, primary care and by embracing the patient-centered
medical home model as an integral part of the Medicare program.
Specifically, the AAFP encourages Congressional action to reform
the Medicare physician reimbursement system in the following manner:
- Repeal the Sustainable Growth Rate formula at a
date certain and replace it with a stable and predictable annual update
based on changes in the costs of providing care as calculated by the
Medicare Economic Index.
- Adopt the patient-centered medical home by giving
patients incentives to use this model and compensate physicians who
provide this function. The physician designated by the beneficiary as the
patient-centered medical home shall receive a per-member, per-month stipend
in addition to payment under the fee schedule for services delivered.
- Phase in value-based purchasing by starting with
the Physician Quality Reporting Initiative. Analyze compensation for
reporting and ensure that it is sufficient to cover costs associated with
the program and provide a sufficient incentive to report the required
data.
- Ultimately, payment should be linked to health
care quality and efficiency and should reward the most effective patient
and physician behavior.
The Academy
commends the Subcommittee for its commitment to identify a more accurate and
contemporary Medicare payment methodology for physician services. Moreover, the
AAFP is eager to work with Congress toward the needed system changes that will
improve not only the efficiency of the program but also the effectiveness of
the services delivered to our nation’s elderly.
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