Massachusetts Medical Society: Comments Regarding Administrative Bulletin 20-27: Rate Update Applicable to Certain Physician Services During the COVID-19 Public Health Emergency

Comments Regarding Administrative Bulletin 20-27: Rate Update Applicable to Certain Physician Services During the COVID-19 Public Health Emergency

On March 30th, Governor Baker issued an executive order providing the Executive Office of Health and Human Services (EOHHS) administrative flexibility to extend financial relief to providers of critical health care that serve EOHHS clients, including members of MassHealth. Per the executive order, EOHHS may extend critical financial support to providers who are facing extraordinary demand due to the COVID-19 emergency or that have lost significant revenue because they have had to cancel other procedures and appointments.

On April 7th, Governor Baker announced a new $800 million investment in Massachusetts health care providers who are critical to the pandemic response. Subsequently, EOHHS issued this administrative bulletin outlining a 15% MassHealth rate increase on the top 100 most utilized codes on the Medicine, Surgery and Anesthesia, and Radiology fee schedules, accounting for approximately $15 million in financial support. The Medical Society is very grateful for the Administration’s efforts in providing additional financial support to physician practices in this time of need.

To date, however, this proposed rate increase is the only mechanism offered in this $800M state package to provide financial relief to primary care physicians and other private practice physicians. While the Medical Society is deeply appreciative of the state’s attention to private physician practices, we do have concerns about the adequacy of this approach as the sole means to provide meaningful financial relief to affected physicians and would appreciate the opportunity to have a continued dialogue as to how the state can best support physician practices struggling under the circumstances of this pandemic.

The Medical Society appreciates the thoughtful approach in selecting a comprehensive set of codes for a 15% rate increase. Indeed, these codes appear to largely capture much of the current services being provided. However, MMS is interested to learn more about the total spend on these codes and when that was calculated. It would be helpful to understand whether there has been significant variation in the use of these codes as the intensity of the pandemic has increased and practices have experienced a dramatic reduction in volume of care being delivered because of social distancing protocols and state orders to cancel non-essential elective procedures.

With the COVID-19 crisis and the ensuing emergency orders affecting the practice of medicine, there has been a sizeable shift in modality of care delivery from in-person care to telemedicine. As such, the Medical Society would recommend that MassHealth consider including telehealth codes in the selected code set subject to the rate increase. It’s likely that these virtual codes were not included because when the code data was analyzed, telemedicine was not as widely utilized as it is today. Allowing for rate increases on telehealth codes will ensure a more meaningful and substantial financial impact for physician practices that are unable to continue providing in-person care or whose care base has largely shifted to telemedicine.

While this rate increase is a good start and accounts for only one piece of the total financial package on both the state and federal levels, the Medical Society remains concerned about whether this rate increase is adequate to address the dire financial circumstances many practices are facing. Private physician practices not supported by a hospital system will not be adequately protected if a MassHealth rate increase is the only measure taken to support these practices.

The financial stability and sustainability of these physician practices is at risk in part as a result of the state ordering to be canceled procedures and appointments that would otherwise provide supportive, sometimes critical, revenue streams either to accommodate anticipated COVID-19 demand or to abide by required social distancing protocols. A 15% increase in MassHealth reimbursement rates is not financially adequate to address the gaping holes in revenue most physician practices are experiencing. Moreover, a rate increase approach inherently disadvantages and will not provide financial relief to physician practices that cannot currently provides services or that have experienced massive reductions in volume because of the COVID-19 crisis. The Medical Society has been hearing from members representative of a wide range in size of independent physician practices in the Commonwealth who have experienced dramatic reductions in volume of care, ranging from 50%-90%. Our concern is that a 15% increase in the MassHealth rates of the remaining volume in care provided to MassHealth patients will not suffice to support the massive deficit these practices are facing.

In addition to these rate increases, the Medical Society recommends the state consider additional mechanisms of financial relief that may more effectively support private physician practices. Specifically, advance payments for MassHealth providers could provide supplemental support that will have an overall meaningful financial impact. This will provide relief to physician practices that are either unable to provide services due to furloughing or laying off staff to cut costs or that have experienced dramatic reductions in volume. This financial support will provide such practices with direct capital and more flexibility to rehire staff, implement telemedicine, and plan accordingly for the future.

Thank you for the opportunity to provide comments regarding the proposed rate increase. The Medical Society greatly appreciates the Administration’s partnership and efforts in supporting physicians impacted by the COVID-19 emergency.

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