American Academy of Family Physicians March 15, 1999
The AAFP Survey of Regulatory Burdens Experienced by Family Physicians Participating in the Medicare Program, and the Federal Government's PRIT Effort
AAFP Statement to the Practicing Physicians Advisory Council
Presented by Neil H. Brooks, M.D., Chair, Board of Directors and Immediate Past President
Introduction
Good afternoon, Madam Chair and members of the Practicing Physicians Advisory Council. My name is Neil H. Brooks, M.D. I am a practicing family physician from Rockville, Connecticut, and I serve as the Chair of the Board of Directors of the American Academy of Family Physicians. The 88,000-member Academy is comprised of practicing family physicians, family practice residents, medical students, and other individuals with an interest in family medicine.
Before turning to the agenda, I want to thank Dr. Kenneth Viste for his excellent leadership as the immediate-past-chairman of the council. He demonstrated considerable tact and fairness in his handling of items brought to the council for action. I also want to congratulate Dr. Marie Kuffner for her selection as chairperson of the council. She is an eloquent spokesperson for practicing physicians, and the Academy looks forward to working with her. Finally, the Academy would like to thank Secretary Shalala for appointing a family physician, Dr. Victor Vela, of San Antonio, TX, to serve on the council. We also would like to congratulate the Secretary for helping to apprehend three car thieves and burglars last week. In a city where a lot of people talk about fighting crime, it is good to find a public official who is actually succeeding in stopping crime.
I am very pleased to appear before you today to comment on efforts by the Physician Regulatory Initiative Team, known as PRIT, to identify the Medicare regulations most burdensome to participating physicians. This is a compelling issue for family physicians. According to the Academys most recent profile of its membership, 83.3 percent of AAFP members participate in the Medicare program. Of this number, 73.3 percent accept new Medicare patients in their practices. Thus, more than four-fifths of practicing family physicians are signed up with the Medicare program and providing health care services to beneficiaries, making family physicians a significant source of health care for our nations elderly and disabled citizens.
Compliance with Medicare rules, therefore, is an important feature of many family physicians daily practice. It is our understanding that the Secretary of Health and Human Services (HHS) and the Administrator of the Health Care Financing Administration (HCFA) will offer a proposal for easing the regulatory burden placed on participating physicians, perhaps as early as this fall. The Academy is greatly encouraged by this development, and appreciates the opportunity to share our recommendations for which Medicare rules should be addressed in the plan that will be eventually presented to the public.
Background
As we all know, Medicare regulations are supposed to serve a useful purpose. The fact of the matter is that sometimes they do but far too often they hinder and confuse. It is no overstatement to say that physicians participating in the Medicare program today are overwhelmed by red tape.
From the moment a physician applies to participate in the Medicare program, to the moment he or she ceases to practice, it is virtually guaranteed that there innumerable regulations, guidelines, or carrier opinions touching upon some feature of the health care services provided to Medicare beneficiaries. Whether it is physician office laboratories, coding, reimbursement, or even death, HCFA likely has issued a rule about it. The rules and the attendant paperwork have, in turn, erected a very real and daunting challenge to simply treating the beneficiary. Indeed, excessive paperwork is one of the primary reasons cited by the nearly 30 percent of family physicians who choose not to accept new Medicare patients in their practices.
It is not possible to over-emphasize the burden of Medicare requirements. All other third-party payers, including state Medicaid programs, are less burdensome in their requirements by orders of magnitude. Medicare is also the one and only program that continually brands physicians as guilty of “fraud and abuse” and creates among the physician community a climate of fear that any honest mistake in traversing the labyrinth of HCFA regulations may result in sizable, adverse civil or, even worse, criminal sanctions.
Having said this, I am nevertheless certain that the administration and Congress do not intend for the Medicare regulations to serve as a disincentive to participation in the program. Unfortunately, this is the state we have reached today under the existing Medicare rules. For this reason, the Academy was extremely pleased by the announcement of the PRIT. Action by the team will lead hopefully to de-regulation of the Medicare program in a manner that promotes high quality health care services and reduces the hassle factor. Indeed, the Academy applauds this self-initiated look at the health of the Medicare program and suggests that HCFA and HHS undertake this sort of preventative maintenance on a regular basis to ensure that Medicare rules are appropriate for both beneficiaries and the health care providers who serve them. This sort of annual check-up could help greatly to alleviate the regulatory burdens of the program.
The AAFPs PRIT Survey
· Methodology
Last year, Academy staff met with Steven Gleason, D.O., an Iowa family physician who is leading the PRIT effort. At that time, we promised to survey our membership about the Medicare regulations that pose the most problems for family physicians, and report the findings to HCFA and PPAC. I am very pleased today to make good on that promise.
In January, the Academys 18 commissions and committees met to conduct regularly scheduled business. It should be noted that an effort is made to identify women, minorities, students, residents, and chapter executives and staff for membership on these panels, as well as to establish regional balance to ensure that committees and commissions are as representative as possible of the Academys membership. Prior to the January meeting, a survey on the PRIT issue was distributed to all 136 commission and committee members. A copy of the survey is attached to this statement and a copy of all responses will be given to the PRIT team and PPAC staff for review. The survey generated 80 responses, which is a 58.8 percent response rate. Given the composition of the commissions and committees, and the results of the survey, I believe the regulations identified in the survey present a reliable illustration of the most burdensome Medicare rules confronting family physicians in their practices.
· The Family Physicians for Whom Medicare Rules Present No Problems
Given the nature of the survey and the PRIT effort, it may be surprising that there were actually three respondents, less than six percent, who indicated they had little to no problems with Medicare regulations. Upon closer inspection, however, the reasons for this positive response are not so encouraging for HCFA and PRIT reviewers. Of the three respondents with little to no problems with Medicare rules, one is a medical student, one is an armed services physician, and the other has fewer than 10 percent Medicare patients in his caseload. The conclusion, therefore, is that only if a physician has few to no Medicare patients, he or she will not have many problems with Medicare regulations.
· Emerging Themes
In the survey responses, unflattering commentary on the Medicare program was interspersed with descriptions of regulations that are problematic for practicing family physicians. This is unsurprising given the purpose of the initiative.
Many respondents expressed dissatisfaction with the performance by staff of the local Medicare carriers. First, as the result of changes instituted recently, physician inquiries about the status of submitted claims are no longer answered by a “live body” but are handled instead via voice mail. This efficiency is bothersome to some family physicians, who prefer that a person, and not a recording, answer the phone. Second, when carrier personnel are reached, they are often unfamiliar with the Medicare regulations and have to transfer the physician to other staff, often several times, before an answer is secured. Worse yet, if the physician follows up or contacts the carrier again about the matter, different staff gives different answers, leaving the physician uncertain about the proper steps to take with a particular claim or matter at issue. Finally, there are reports of rudeness by some carrier staff and lengthy delays in obtaining answers to inquiries.
Dissatisfaction with the performance by some Medicare carrier staff exacerbates the feeling that doctors are surrounded by an “aura of criminality,” as one family physician described it. The rules are often confusing, and receiving conflicting answers to inquiries from carrier staff frustrates family physicians and their staff and can increase their fears about unintentional non-compliance with Medicare program requirements. The Academy believes that physicians should not be punished for human error. Staying “on top” of the regulations, however, can be more than difficult. There are literally thousands of pages of regulations concerning covered services, billing, lab practices and so forth. Notifications of changes in the regulations are not always sent in a timely fashion and even if they were the sheer bulk would make them uninterpretable except, perhaps, by a full-time bureaucrat. To make matters worse, since passage of the Health Insurance Portability and Accountability Act (HIPAA) with its heightened criminal and civil monetary punishments, HHS officials have joined with the AARP in an ill-advised national campaign to utilize Medicare beneficiaries as fraud busters to help HCFA detect incorrect billing by participating physicians. In this environment, can physicians be faulted for feeling a bit nervous? The widespread assumption, fueled by Medicare rules, the national fraud-buster campaign, media reports and some HCFA practices, seems to communicate to the public that physicians are “guilty until proven innocent.” In this environment, the Academy is now strongly advising its members to familiarize themselves and their staff with Medicare billing rules, so as to be prepared for the anticipated increase in inquiries about Medicare bills. This is not advice we like giving since it means cutting back on patient care to find the time to respond to the anticipated rise in billing inquiries.
Regardless of this development, it should be noted that family physicians and the Academy are absolutely committed to rooting out fraud, waste and abuse in the Medicare program. We are, however, extremely concerned about the potential for adversarial feelings and distrust seeping into the physician-patient relationship because of the exaggerated claims of the extent of Medicare fraud and abuse, and aggressive anti-fraud and abuse programs initiated by the government. This adversarial environment is fueled, some family physicians feel, by the complexity of Medicare rules. Many respondents noted that the Medicare program is increasingly inflexible, and that they feel they are losing control of medical decision making.
An Overview of the Survey Results
There was a remarkable similarity in survey results across all of the country. This indicates to me a consensus about the Medicare rules that pose the most problems for practicing physicians. I would not be surprised if many of the same rules are equally problematic for other medical specialty groups.
The following is a list of the Medicare regulatory issues identified most frequently in the AAFPs survey of significant problems for practicing physicians:
- medical necessity rules, including denials, advanced beneficiary notices, home health care certification of “homebound” status and care plans, the requirement of diagnosis codes to bill for laboratory services, and the ordering of durable medical equipment (DME),
- the evaluation and management documentation guidelines,
- teaching physicians and medical student documentation,
- reimbursement for multiple procedures on the same patient on the same day,
- the pressing need for uniformity in coding and forms used by local Medicare carriers and HCFA,
- the exacerbated impact of regulatory hassles in rural settings,
- lengthy delays in the enrollment process for new physicians,
- the need for additional, non-physician provider numbers on some claim forms, and
- variability between local carriers and intermediaries.
AAFP Results Issue-by-Issue Medical Necessity Rules
· General
Many of the regulatory burdens cited by family physicians relate to HCFAs attempts to ensure the “medical necessity” of services furnished to Medicare beneficiaries.
We recognize that the law requires, as a general condition for coverage, that services to Medicare beneficiaries be reasonable and “necessary” for the diagnosis or treatment of an illness or injury. We also recognize that part of HCFAs responsibility is to ensure that this general condition of coverage is met in each case. However, we believe that in its attempts to fulfill this responsibility, HCFA has inadvertently created a myriad of unnecessary burdens and hassles for physicians.
Indeed, HCFAs use of the term “medically necessary” is problematic in and of itself. For example, when HCFA or a Medicare contractor communicates to a beneficiary that it is denying payment for a service because it was “not medically necessary,” it often creates the impression with the beneficiary that the service was “not medically appropriate.” This, in turn, creates a potentially disruptive and adversarial situation between the physician and patient when, in fact, the service is medically appropriate, based on generally accepted medical practice, but simply fails to meet Medicares coverage criteria. To avoid this more general problem, we urge the council to recommend that HCFA use more accurate language, such as “not consistent with Medicare coverage criteria,” in instances for which coverage is denied.
· Advanced Beneficiary Notices
A more specific issue related to “medical necessity” is the requirement that a physician must have a beneficiary sign an “Advanced Beneficiary Notice” (ABN) before providing services that the physician believes Medicare may deny for reasons of “medical necessity” in order to subsequently collect from the beneficiary. Through this requirement, HCFA shifts the onus for knowing and understanding the scope of Medicare coverage from the beneficiary to the physician. Yet, it should be the beneficiary who is presumed to have the most interest in and knowledge of this matter. Indeed, in not requiring an ABN for excluded services (e.g., preventive medicine visits), HCFA explicitly assumes the Medicare beneficiary understands the limits of his or her Medicare coverage.
We believe it is the responsibility of the beneficiary, not the physician, to know the limits of their Medicare coverage. Thus, we recommend that the council urge HCFA to eliminate the ABN requirement, or else allow physicians to execute some sort of one-time, “blanket” ABN that would alert beneficiaries that they are responsible for services Medicare denies on the basis of its own coverage criteria. This recommendation should not affect quality patient care, since physicians will continue to recommend and provide what they believe to be the most appropriate care for their patients, regardless of the need for an ABN. Further, we note that many private insurers affect many of the same “medical necessity” restrictions without the additional paperwork required for Medicares ABN.
If HCFA is unwilling to eliminate the ABN requirement, then we would like the council to recommend that HCFA provide physicians with a standard ABN form that they could rely upon to meet this requirement. If the ABN requirement is maintained, we would also like the council to recommend that HCFA eliminate the necessity of adding the -GA modifier to the claim when an ABN is involved. It is unclear that the addition of the modifier changes how the claim is processed, and it does not change whether or not the physician actually has an ABN on file. All it seems to do is add to the hassle of billing the services in question.
· Home Health
Another specific issue related to “medical necessity” concerns the physicians responsibility for certifying plans of care for home health agencies. First, physicians resent the necessity of completing what amounts to someone elses paperwork. As a form, the signed plan of care helps secure coverage for, and reimbursement of, services provided by the home health agency. It does not add anything to the physicians treatment of the patient.
Beyond that, physicians find the forms difficult or nearly impossible to read and having little to do with medical reality. If HCFA is going to require physicians to continue to complete and sign these forms, then we ask the council to urge HCFA to simplify and reformat the forms in a way that makes more sense to physicians.
The need to certify the patients status as “homebound” is also problematic. In general, according to HCFA, a patient is confined to the home if his or her condition creates a "normal inability" to leave home and if, consequently, leaving home would require "a considerable and taxing effort." However, patients who do leave the home may still be considered homebound if the absences from the home are infrequent, for relatively short periods, or are due to appointments to receive medical treatment. HCFA expects that most absences from the home will be for medical treatment, but acknowledges that occasional absences from the home for non-medical purposes (e.g., a trip to the barber or a walk around the block) do not necessarily mean that the patient is not homebound. Thus, a physician certifying a home health plan of care is left to wonder just how much a beneficiary can be out of the home and still be considered “homebound” under Medicare. We ask that the council request of HCFA clear and straightforward guidance on what “homebound” means; otherwise, if the present, very uncertain definition is kept intact, physicians should be relieved of liability in cases where local carriers find that a beneficiary is not homebound for purposes of Medicare coverage.
· Laboratory Services
A third specific area of “medical necessity” hassles relates to ordering laboratory services. We recognize that the law requires physicians to provide diagnostic information when ordering laboratory tests for Medicare patients in order to establish the “medical necessity” of such tests. While this requirement, in and of itself, is not particularly problematic, the local medical review policies that carriers have developed as a result have created an administrative nightmare for physicians. Often, these local policies are not comprehensive enough in terms of the covered diagnosis codes they associate with a given laboratory test, as family physicians, who often order such tests to address undifferentiated symptoms and diagnoses, seem to readily discover. Further, the policy for a given test seems to differ from carrier to carrier, so physicians serviced by multiple carriers must be attuned to multiple policies for the same test.
We understand that HCFA is currently engaged in a negotiated rulemaking process that will address at least some of these concerns, and the Academy has provided its input to this process at every available opportunity. As HCFA proceeds with this process, we would encourage the council to weigh in by urging the agency to think comprehensively when identifying the lists of covered diagnoses for each test. We would also ask the council to join us in encouraging HCFA to consider prohibiting its carriers from establishing local policies for tests not covered by the negotiated rulemaking process. We recognize that this recommendation runs contrary to HCFAs normal approach of allowing Medicare carriers to establish local policies in the absence of national policy. However, we would argue that, in this instance, if HCFA has not deemed a particular lab test as problematic enough to establish a national policy, then the test does not require a local policy either.
PRIT members, HCFA staff and the council may be interested in the tests mentioned by our survey respondents. These tests include complete blood count (CBC), Chem-7, urinalysis (UA), thyroid stimulating hormone (TSH), blood glucose, cancer antigen 125 (CA-125), carcinogen embryonic antigen (CEA), Ferritin, Hemoccults, and the prostate specific antigen (PSA) screen.
· Durable Medical Equipment
The last problem area that we want to highlight under the heading of “medical necessity” is perhaps the most important one. It concerns the need to complete and sign Certificates of Medical Necessity (CMNs) for durable medical equipment (DME), including home oxygen. Historically, HCFA allowed DME suppliers to complete the CMN and then forward it to the physician for review and signature. However, in recent years, HCFA has increased the burden on physicians who order DME by requiring that they, rather than suppliers, complete most of the CMN. As with the home health plan of care, completion of the CMN is a pure hassle in that it makes the physician responsible for doing someone elses paperwork.
Also, we question why it is necessary for the physician to actually complete the CMN, given that he or she must review and sign it. The physician signature is enough to hold the physician responsible for the contents of the CMN without requiring the physician to actually fill out the contents.
There also is a question about the criteria for coverage of DME. Some of our physicians believe these criteria are too restrictive and recommend that HCFA re-examine them. For example, one of our members noted that as a condition of coverage, the physician may be asked to recertify the need for a particular piece of DME every few months even though the physician certified initially that the patient will require the DME on a lifetime basis. Such seemingly unnecessary recertification increases the physicians workload without any apparent benefit to the patient. We concur and urge the council to recommend that HCFA re-examine its coverage criteria for DME, especially as these criteria relate to recertification of equipment required on a lifetime basis and the duties of the physician with respect to the CMN.
Evaluation and Management Documentation Guidelines
This council has examined the issue of the evaluation and management (E/M) documentation guidelines several times during the past year. The family physicians who identified the E/M documentation guidelines as a Medicare burden felt quite strongly about the issue. All of them stated that the documentation requirements detracted a great deal from clinical practice. As one respondent noted, “This requirement has left physicians feeling so frustrated that I am aware of several who have retired early because of concerns about meeting this paperwork burden.” Essentially, the E/M coding and documentation requirements have, in the opinion of many family physicians, become so complex and onerous that physicians are perplexed as to how to maintain medical records that assist in patient care while complying with federal law regarding billing.
Family physicians believe the E/M documentation guidelines should be greatly simplified and made more user-friendly. The Academy also urges the council to recommend that if HCFA insists on scoring elements as part of the E/M documentation guidelines, then HCFA should also be responsible for distributing a template for typical patient encounters, as well as software for electronic medical records to ease the burden of billing documentation.
Medical Student Documentation and Teaching Physicians
As many of our members stated, the Medicare rules affecting family physicians involved with teaching medical students has generated a great deal of confusion about appropriate billing that needs to be clarified. Because of the confusion, physicians are under the impression that they must completely duplicate a student's notes as part of their duties. This, in turn, is a disincentive for family physicians to become involved in teaching. We learned through our survey that some community physicians are refusing to take any more medical students in their practices on the basis that it is an increased hassle to their practices because duplicating students' notes is time consuming, costly, and does not improve the quality of patient care. This situation clearly is worrisome and disruptive.
It should be noted that significant improvements were made in 1996 in Medicare's teaching physician regulations with respect to supervising residents. The Academy greatly appreciated HCFA's willingness to listen to our suggestions for improving the rules and to adopt a primary care exception that is quite helpful to family medicine training programs nationwide. However, at issue today is a separate issue involving patient care services when a student is present. At issue is what the Medicare rules should permit with respect to billing when a student note is in the patient's medical record, and how the rules are supposed to be applied in such situations.
Currently, Medicare does not recognize students; they are the invisible women and men of medicine. Yet, the Academy believes that the work of students is no less valid than the work of nurses or of patients themselves in contributing to the patient encounter. Indeed, as all practicing physicians know, nurses take a history, later corroborated by the physician, of the chief complaint and history of present illness of the patient, if not more. They also take vital signs, usually not later corroborated by the physician, but used nevertheless in medical decision making. Patients often fill out medical history forms themselves, which physicians also use in medical decision making.
Medical students perform many of the same functions as nurses and patients, such as taking medical histories. Accordingly, we believe that referring to the work of a student that is documented in the medical record is like referring to the work of nurses or patients that is included in the record. In such circumstances, the physician is taking responsibility for the services provided to the beneficiary by attesting to the note written by the student, either agreeing in full, or in part with it, and adding whatever additional observations are needed. The physician is of course conducting his own physical exam and assessment, which may corroborate in full or in part what the student has done.
Thus, the Academy strongly recommends that HCFA should accept a student note for Medicare billing purposes if the physician, in his or her note, attests to the fact that the medical decision making is predicated on information put in the medical record by others, but for which the physician takes full responsibility.
In the final analysis, we firmly believe that under this approach to billing which allows information included in the student notes to be used. Namely, HCFA is getting what it pays for -- beneficiary health care services performed by a physician -- while facilitating the training of future physicians in the ambulatory setting. This is a worthy goal, and one that we hope PRIT will include in its final plan.
Reimbursement for Multiple Services for the Same Patient on the Same Day
Some respondents feel that current Medicare regulations unfairly reduce or deny for the work a physician provides in furnishing two or more services to a beneficiary on the same day. The situation in which multiple services are furnished to one patient on the same day is common enough in the family practice setting. We ask the council to recommend that HCFA review its payment policies with respect to the physician work involved in providing multiple procedures to a patient on the same day.
Call for Uniformity in Coding and Forms Used by HCFA and Carriers
Several family physicians noted that HCFA in some cases uses HCPCS coding for processing claims, instead of the more widely recognized CPT coding, and that this practice is very confusing. For example, one respondent noted that the HCFA requirement that a screening pelvic and clinical breast exam be billed as a G0101, and that a pap smear be billed as a Q0091 in accordance with the HCPCS system, is not recognized by most secondary payers. This situation forces physicians to recode their claims for these services when submitting claims to secondary payers, thereby creating extra paperwork and reducing the time spent in direct patient care. For these reasons, the Academy is asking the council to urge HCFA to deviate from CPT coding as infrequently as possible, and to work through the CPT editorial process to improve coding instead of establishing more HCPCS codes.
The Impact of Medicare Regulations in Rural Care Settings
Determining whether a beneficiary is homebound is particularly difficult in the rural setting, according to some family physicians. The new OASIS requires a lot of time for documentation, which is a burden for physicians and their staff. Further, rural physicians report that the Medicare manual is too bulky and large, making it difficult to use when needed. In general, basic interactions between participating physicians and local carrier staff are often more difficult to carry out because of the challenges and limitations of rural or frontier practices. We therefore ask the council to recommend that HCFA renew its efforts to accommodate the needs of rural by taking into account the challenges and limitations posed by the location of their practices, so that they can serve beneficiaries with a minimum of regulatory hassles.
Enrollment Hassles
New physicians and physicians changing positions or employment arrangements report that it takes as long as six to nine months to obtain a provider number from their local carrier. Some family physicians remarked that HCFA Form No. 855 should be streamlined, and that simple modifications, such as address and name changes, should be completed within 10 or fewer business days. Further, AAFP respondents strongly encouraged HCFA to accept changes by fax. The Academy concurs with these suggestions and urges the council to ask that HCFA streamline the process for giving physicians their Medicare provider numbers so that the enrollment period is substantially shortened.
Multiple, Non-Physician Provider Numbers on Claim Forms
A family physician argued that it is burdensome to provide more than one provider number on claims submitted to local Medicare carriers and intermediaries. The complaint arose from a situation in which a nursing home patient was admitted to a hospital for treatment. According to the physician, he was required to enter both the nursing home and the hospitals provider numbers on the claim form for his services although none of this information was related to the professional services that he furnished the patient. We agree that physicians should be required to provide only the information relating to their services that is necessary for submission of a Medicare claim. Other providers should complete their own paperwork in order to receive payment.
Variability in Local Carrier Medical Policies
Physicians enrolled in group practices with locations in different states mentioned that it is difficult to monitor and comply with several sets of local carrier medical policies. Family physicians in these sorts of practice arrangements argue that state-to-state variations in coverage policy should be minimized as much as possible. Further, they argue that if a lab test is covered by Medicare Part A when performed in an outpatient hospital, the same test should be covered by Medicare Part B if performed in a physicians office. Finally, respondents noted that local carrier policies should not be drafted to target a few physicians. Instead, the carrier staff should personally contact and investigate physicians displaying aberrant billing practices. We concur with these suggestions and recommend that the council urge HCFA to take steps to reduce variability in medical policies between local carriers in cases where such action is appropriate.
Problems Requiring a Legislative Solution
Family physicians also identified the rules concerning skilled nursing facility (SNF) placement and the operation of physician office labs as problematic for practicing physicians. These issues, however, require a legislative -- not a regulatory solution.
· SNF Placement
Some survey respondents feel that the statutory requirement of a three-day period of hospitalization prior to placement in a skilled nursing facility is unnecessary, costly, and burdensome for patients requiring SNF care. We agree. Therefore, the Academy is asking the council to join in recommending that HCFA propose legislation to eliminate the prior hospitalization requirement for SNF placement.
· Physician Office Laboratories
Many family physicians have drastically curtailed the provision of basic laboratory diagnostic services in their offices since enactment of the Clinical Laboratory Improvement Act of 1988. Indeed, the most recent Academy survey to profile our practicing members found that 52 percent of practicing family physicians have eliminated some office testing because of CLIA requirements, and additional 8 percent have completely eliminated office laboratory services because of CLIA. The Academy has consistently argued that government micro-management of physician office laboratories is unwarranted and inconsistent with cost-effective, high-quality and accessible health care services.
The Academys PRIT survey respondents noted that CLIA requirements are so onerous that some physicians have, as noted above, stopped furnishing some laboratory tests. This is extremely unfortunate since it severely inconveniences the patient and appropriate and timely screening may not be done. Accordingly, the Academy is strongly supportive of efforts to enact an exemption from CLIA requirements for physician office laboratories. This goal is precisely what H.R. 528, the “Clinical Laboratory Improvement Act Amendments of 1999” introduced by Representative Bill Archer (R-TX) would achieve. The Academy urges the council to strongly recommend that HCFA support passage of H.R. 528 in the 106th Congress.
Conclusion
As noted earlier, the American Academy of Family Physicians is very encouraged by the establishment of the Physician Regulatory Initiative Team. We are hopeful that the contribution represented by our survey on burdensome Medicare rules will be of assistance to Dr. Gleason and other PRIT members as they develop a proposal for alleviating the regulatory hassles experienced by physicians participating in the Medicare program. At this time I would be pleased to answer questions from members of the council.
AAFP Statements to Advisory Panels |AAFP Home | Search