NCCS Submits Comments to CMS on the Proposed 2025 Physician Fee Schedule

NCCS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed Physician Fee Schedule for CY 2025. Specifically, NCCS’s comments focused on the codes put in place in CY 2024 to reimburse principal illness navigation (PIN), community health integration (CHI), and social determinants of health (SDOH) assessment.

We noted several barriers to implementation and utilization of the codes, including billing system modifications needed by practices, as well as the cost-sharing that patients will be required to shoulder. We do not believe that the challenges are insurmountable, as Medicare PFS codes always have a long lead-time for implementation.

We noted that some oncology practices, including ones who participated in the Oncology Care Model, are using a model of navigation that relies on practice resources and does not engage auxiliary personnel as navigators. We urged CMS to consider codes in this family of codes that would reimburse for a different model of navigation services.

We recommended that CMS create two codes for cancer survivorship care. One code would provide for the development of a summary of the active treatment the patient received and a plan for surveillance and follow-up care and should be billed in the first month after transition from active treatment (and perhaps the second). A second code would reimburse for cancer survivorship navigation services in the months after the survivorship plan is developed and provided to the patient.

Read the letter below or download here.

In addition to NCCS’s letter, NCCS joined with the National Alliance for Caregiving’s Cancer Caregiving Collaborative in a letter addressing the Caregiver Training Services code.