PCC’s COVID-19 Policy Priorities

PCC's Request of the Administration to Support Primary Care

PCC, representing over 60 organizations, sent on June 1, 2020, a letter to Department of Health and Human Services Secretary Alex Azar urging him “and the Department of Health and Human Services (HHS) to make an immediate, targeted allocation from the Provider Relief Fund (PRF) to primary care clinicians and/or practices in order to offset reduced revenue and increased costs associated with COVID-19.” Read the full letter.

In addition, the PCC is advocating to:

Waive Patient Cost-Sharing to Eliminate Barriers to Primary Care

Families across the country are facing increasing financial strain as the economy continues to falter in the wake of the pandemic. As they face difficult daily trade-offs on what to purchase and what to forgo, the decision to access essential primary care services should not be one of them. Health plans, including high-deductible plans, should be encouraged and allowed to waive all cost-sharing, including deductibles and co-pays, for primary care services during the public health emergency to ensure that patients can continue to access care when they need it. This cost-sharing waiver should apply to in-person, video, and telephonic visits so that patients can access remote services when appropriate, lowering the risk to themselves and providers of contracting the virus.

Offer Payment Parity in Commercial Plans (Telehealth and In-person Visits)

Telehealth is a critical healthcare tool during the pandemic, allowing  patients and clinicians to limit their exposure to the virus. These virtual visits should be paid equal to in-person visits. CMS and select commercial plans have announced payment parity for the duration of the COVID-19 emergency. Now the remaining commercial payers and state Medicaid programs should follow suit. Additionally, these rates should be set to reflect that practices will waive patient cost-sharing for telehealth visits, both COVID-19-related and otherwise, during the emergency period to encourage patients to access remote services.

Provide Adequate Reimbursement for Telephone Calls

We applaud CMS’s announcement on April 30 that traditional Medicare will pay for phone calls at parity with in-person visits. Medicaid, Medicare Advantage plans and private health plans should follow CMS’s lead and adequately reimburse for telephonic visits during the public health emergency. According to week 6 data from the Larry A. Green Center’s COVID-19 survey, 44% of primary care clinicians are using the telephone for the majority of their visits. Yet practices are receiving little to no reimbursement for most of these calls, as parameters for telehealth require both audio and visual capabilities that necessitate patient access to the internet and a webcam or smartphone. This poses a barrier to patients who lack access to reliable broadband or may face challenges navigating new online platforms. Providing parity for audio-only visits will allow at-risk patients to easily access their providers by telephone, and it will allow practices to receive much-needed revenue for the high volume of calls they are already managing without reimbursement. Telephonic billing codes should be “turned on” quickly for a range of services, including COVID-19-related care, as well as routine medical care, chronic disease management, and mental health consultations. These codes should be set fairly, at rates equivalent to in-person visits, for the duration of the public health emergency. Payers should also process telephonic claims quickly to ensure practices receive much-needed revenue in a reasonable timeframe.

Support Advance Payments to Primary Care; Reinstitute the CMS AAP Program

Public and private payers should offer advance payment options to primary care practices to help keep them afloat during this difficult time. CMS took the lead on this in March when it expanded its Accelerated and Advance Payment (AAP) Programs to offer providers short-term financial support by pre-paying for Medicare services based on a provider’s pre-COVID-19 billing. Yet the agency recently announced that it was suspending the payments. While PCC has advocated for changes to the program, including an extended repayment period, we believe that the advance payments offer primary care practices much-needed short-term relief and call on CMS to quickly re-institute it for the duration of the pandemic emergency period. 

Select commercial plans have also started to offer advance payments, though it’s not yet widespread. See the PCC’s growing Health Plan Honor Roll for the latest list. Other health plans should consider offering this option for strained practices to access the cash flow needed to stay viable. Some fully insured commercial plans, Medicaid MCOs, and Medicare Advantage plans are capitated (i.e., paid per-member-per-month) and could advance funds for plan enrollees that are empaneled or otherwise attributed to a primary care clinician/practice. Self-insured plans could advance expected visits and reconcile with practices at the end of the year. CMS should also consider extending advance payments to practices participating in the Comprehensive Primary Care Plus program. CPC+ practices are also facing financial strain and would benefit from receiving advance care management fees and primary care prospective payments (for Track 2) that could be recouped through reduced payments after the emergency period ends

Ensure All Frontline Clinicians Have Adequate PPE

Primary care clinicians on the front lines continue to face shortages of equipment to keep themselves safe. Over half (54%) of surveyed primary care clinicians report the use of “used and homemade PPE” (Green Center Survey, April 17-20). Federal, state, and local governments must use all means necessary to ensure that every frontline healthcare clinician has access to adequate PPE. This should be pursued through a range of avenues including dedicated funding support, the creation of state-based online systems for requesting PPE, and regulations focused on increasing and prioritizing manufacturing and distribution capacity. Congress, the Trump administration, and states have all taken some steps to respond, but sustained attention to this issue must continue until it’s fully resolved.  

Pay CHWs for Contact Tracing and Connecting Patients to Social Services

Congress should increase Federal Medical Assistance Percentages (FMAPs) to states to support enhanced Medicaid payments to community health workers (CHWs) during the public health emergency and the immediate 12 months after when public health strategies must be maintained to keep the virus in check. CHWs can play an essential role in responding to COVID-19: First, they offer a well-positioned and capable workforce to perform contact tracing to track and contain the spread of the virus; second, they perform critical outreach to patients who are home-bound during the crisis and facing increasing economic strain and mental illness by connecting them to social services in their communities. CHWs should be paid to perform contact tracing for Medicaid patients and to connect Medicaid patients to health-related social services, both paid as medical assistance at an increased FMAP rate.