ANA Comments on Medicare Physician Fee Schedule

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ANA commented on the Centers for Medicare and Medicaid Services (CMS) proposed regulations associated with the Medicare Physician Fee Schedule. ANA focused its MFS comments on telehealth, the Physician Compare website, “incident to” claims, and complex chronic care management services (CCCMS).

ANA proposed that "incident to" billing be eliminated for APRNs and that NP and CNS services be paid at 100% of the physician fee schedule rate. Further, because Medicare is a national program, ANA recommended that Congress adopt a national scope of practice for APRNs who provide services to Medicare patients, as has been accomplished by the Department of Veterans Affairs and the Defense Department.

ANA also proposed that CCCMS should be reserved for Medicare patients with four or more chronic conditions and that CCCMS can be provided by APRNs and RNs.

Read ANA’s official comments.