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USAging Responds to CMS Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) issued the CY 2025 Physician Fee Schedule proposed rule which included new coding and payment for caregiver training services (CTS) for direct care services and supports and a feedback request on the relationships between community-based organizations (CBOs) and billing practitioners. USAging submitted a comment letter applauding CMS for establishing a new coding pathway for CTS and their efforts in understanding health care and social care partnerships.  
 
While CMS recognized the importance of the direct care workforce, the proposed rule's restriction on eligible CTS providers to only include “clinically based” professionals is a major limitation. USAging emphasized the expertise of AAAs in providing caregiver education and urged CMS to include them as an eligible CTS provider. USAging also highlighted the many challenges faced by AAAs when contracting with Medicare billing practitioners including the volume of referrals met without pay, price and contract negotiations, the time it takes to establish a contract and others. Overall, USAging recommended CMS to provide AAAs and other CBOs with a clear and leading role in addressing health-related social needs through contracts with Medicare providers.  
 
The final rule will be effective on or after January 1, 2025. If you have any questions about the letter or any other policy matters, please contact your policy team at policy@usaging.org.  

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