The Centers for Medicare and Medicaid Services (CMS) and Congress have begun to develop and test different approaches to better manage care for chronically ill beneficiaries. This has included the promotion of Chronic Care Management (CCM) to better control costs while improving the quality of care and outcomes for Medicare beneficiaries suffering from multiple chronic conditions. More specifically, CMS has supported the testing of innovative approaches including the use of home-based primary care teams to improve beneficiary health for this difficult to manage patient population while controlling costs.

Within CMS' proposed Medicare rule for the 2015 Physician Fee Schedule, the agency proposed reforms to practice standards, payment, and supervision of clinical staff requirements for providers furnishing CCM services in addition to myriad other issues.

Kindred used the public comment period as an opportunity to specifically address CCM, promote the ideas contained within ourBlueprint for Post-Acute Care Reform, highlight Kindred at Home's Home-Based Primary Care program, and illustrate how CMS' CCM proposals align with Kindred's strategic goals.

Kindred Recommendations

Within Kindred's specific recommendations to CMS:

  • "We commend CMS for streamlining the formerly proposed practice standards by making standards general rather than specific. This will enable greater and more varied provider participation, especially by eliminating practice elements that are of high cost, yet unproven outcome-related value.
  • "While important, we urge CMS not to be overly prescriptive in requiring written authorizations for CCM, which could inadvertently limit the scope of this important service."

The Kindred Experience

Our comments also sought to illustrate how Kindred has already put CCM into practice, and how proposals within the rule could enhance that ability:

"Kindred's Home-Based Primary Care (HBPC) program plans to use the CCM payment to operationalize regular comprehensive care plan meetings, driven by each patient's goals of care, their specific medical conditions, and their needs. Development of a formal plan of care for each patient will be a centerpiece of this effort. To date, our HBPC program has reduced hospitalizations by approximately 67 percent, 30-day all cause readmissions to 7 percent, and enables 85 percent of our terminally ill patients to die at home."

Next Steps

CMS will take into account all stakeholder comments in crafting its final physician fee schedule rule, which will be issued later this fall in early November. The payment changes and regulatory updates will go into effect on January 1, 2015. We will provide updates upon issuance of a final rule.