Advocacy Work Beyond the Legislature

ADVOCACY

By Gregory K. Griggs, MPA, CAE

NCAFP Executive Vice President

~ REPRESENTING FAMILY MEDICINE ~

Occasionally, I like to update our members on some of our non-traditional advocacy work, that I think can pay dividends that are bigger than even legislative advocacy. So, for this article, I’m highlighting some of our efforts that don’t always receive the most attention.

Workforce

When it comes to increasing the workforce pipeline, collaboration is the name of the game. Our biggest collaborator of late has been Community Care of North Carolina. For example, CCNC has partnered with our Foundation to provide medical students and residents greater exposure to various practice settings within primary care. Through that effort, we have jointly developed a curriculum for residency programs, which can also be utilized with medical students and new physicians. Some of the modules that have been jointly developed include: Models of Care, Employment Contracts, Practice Structure, and more. We have already presented these to a few of our state's residency programs and as part of this year’s Family Medicine Day. We are also working together to increase teaching and mentoring of medical students.

In November, I have the privilege to represent your profession on a primary care workforce panel at the NC Institute of Medicine. I’ll be discussing a few policy levers that should be utilized to increase family physicians, and other primary care providers, in rural areas, including economic incentives. Beyond the NC IOM, we continue to participate in the activities of the NC Center on the Workforce for Health. This Center is a joint project of the NC AHEC Program, the NC IOM and the Foundation for Health Leadership and Innovation. The multi-stakeholder group is looking at future workforce needs to help make a healthier North Carolina and is meeting quarterly to develop solutions.

We also meet quarterly with the President/CEO & Vice President of Government Affairs of the NC Healthcare Association. One of our key areas of discussion has been on workforce needs but has also ventured into the scope of employed physicians and more.

Practice Environment/Payor Relations

As Medicaid Managed Care moves into its second year, we still remain very engaged with the NC Department of Health and Human Services, particularly with Deputy Secretary for Medicaid David Richard and Medicaid CMO Dr. Shannon Dowler. We continue to provide feedback on implementation and have turned our attention to concerns about when tailored plans ultimately go live. Some of the concerns we offered fed into the decision to delay Tailored Plan implementation from December 1, 2022, to April 1, 2023.

Speaking of Medicaid plans, we continue to meet monthly with representatives of Healthy Blue, quarterly with AmeriHealth Caritas, and on a regular basis with WellCare and United. Because of our relationships with them, we were recently able to help one practice get paid for claims that were denied because they were not timely filed, but the filing problem was related to a cyberattack. We continue to pass feedback we hear from you on to the plans as we work to reduce your administrative burden.

In the last few months, we have been involved with a NC Medical Society Task Force looking to relieve administrative burden and other payor issues. Specifically, many groups are working together through the Task Force to develop ideas and policy levers to reduce prior authorizations, network issues with payors and more.

Collaborative Care Model Moving Forward Statewide

Earlier this Fall, representatives of the NCAFP (including NCAFP President Dr. Dimitrios Hondros, Board Member Dr. Mark McNeill and NCAFP EVP Greg Griggs), gathered with colleagues from the NC Psychiatric Association and the NC Pediatric Society, as well as representatives of NC Medicaid, the NC AHEC Program, Community Care of NC, and others to celebrate the completion of a planning effort to move the Collaborative Care Model (CoCM) forward in NC. This evidence-based model helps provide behavioral health services in primary care practices by using a consulting psychiatrist, a behavioral health care manager, and a family physician to partner to provide care for patients with co-existing behavioral health issues or substance abuse using a population health model.

Some of the outcomes of the planning phrase include contracting to provide the AIMS Registry for smaller practices in North Carolina (Community Care of NC is lead in this effort), developing a model contract for primary care practices and consulting psychiatrists (NCAFP and NC Psychiatric Association led this effort), developing a list of psychiatrists willing to consult in this model, and developing practice support materials and education that will be provided by the NC AHEC Program.

NC AHEC has developed a CoCM Training Series that describes the principles of Collaborative Care, identifies the key concepts and care roles for effective implementation, explains the use of and evidence for measurement-based care, and discusses the contributing factors to successful implementation. The series of 10 modules will be issued on a monthly basis. Module 1 is entitled Collaborative Care Model (CoCM) Rationale and Evidence. In addition to these learning opportunities, NC AHEC will provide coaching support to practices that accept Medicaid.

For more information about practice support, email practicesupport@ncahec.net We are very pleased to work with the Medical Society through this Task Force to address some of these issues. These aren’t easy issues to resolve, but the power of many can make a big difference.

Other

We also remain involved in numerous other organizations. Member of your NCAFP staff or NCAFP physician leaders participate in numerous public health working groups such as the NC Immunization Coalition, the Justus-Warren Heart Disease and Stroke Prevention Task Force, the NC Colorectal Cancer Roundtable, the NC Cancer Control and Coordination and Advisory Committee, Medicaid Advanced Medical Home Technical Advisory Group, and many others.

We also continue to give feedback on many issues. Most recently, we commented on a NC Medical Board proposed Position Statement on Employed Licensees, noting concerns with restrictive covenants, negotiating with large employers, and more.

Finally, we are at many tables. Remember, if you aren’t at the table, you may be on the menu. The NCAFP works to be at as many tables impacting your professional environment as possible. Recently we attended an event celebrating the 75th Anniversary of the Kate B. Reynolds Charitable Trust and the Foundation for Health Leadership and Innovation’s Bernstein Dinner. In both instances, we were able to network with health care policy leaders from throughout the state.

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PRACTICE ADVOCACY Blue Cross NC Updates Guidance on Coding for Vaccine Counseling and Separate Vaccine Administration and Counseling Codes

Outreach by NCAFP and NC Pediatric Society Creates Action

Some claims for vaccine counseling codes have recently been denied and even recouped from Blue Cross and Blue Shield of North Carolina. However, after NCAFP and the NC Pediatric Society expressed concerns about this issue, Blue Cross NC issued updated guidance and are helping practices correct the issue. They have also ceased recouping any unpaid claims.

The claims that were not paid or attempted to be recouped were done so because of coding edits from the National Correct Coding Initiative (CCI). CCI was created to prevent unbundling and the incorrect or inaccurate billing of a combination of codes. These are also called CCI edits. CMS identifies individual services that are components of a more inclusive service using the CCI edits.

One example of a Correct Coding Initiative edit relates to the E/M codes 90460 and 99401.

• 99401 - Preventive medicine counseling and/or risk factor reduction intervention(s) provided to an individual (separate procedure); approximately 15 minutes

• 90460 - Immunization administration through 18 years of age via any route of administration, with counseling by physician or other qualified health care professional; first or only component of each vaccine or toxoid administered.

CPT code 99401 is not specific to counseling for COVID vaccines and because counseling is inclusive with code 90460, it is designated a CCI edit by CMS. Therefore, without a modifier to indicate a significant and separately iden-

PRACTICE & tifiable service, such as modifier 25 to ADMINISTRATIVE 99401, the CCI edit will link the coun-

ADVOCACY seling services as already built into the administration, per the code descriptor. Billing a claim with a COVID diagnosis would not affect the CCI edit since diagnosis codes are not part of CMS' procedure-to-procedure (PTP) CCI edit. Counseling is included in any vaccine administration, per code definition. If counseling is provided for COVID or any other vaccine, outside of a vaccine that was actually administered, Blue Cross NC does consider that separate counseling reimbursable, but it must be appended with an appropriate modifier, such as 25 or 59, to indicate it is separate and distinct. You may review the Blue Cross NC reimbursement policy here. Blue Cross NC identified claims in which the two codes 99401 and 90460 were not billed with an appropriate modifier, and therefore were denied reimbursement. Thanks to the joint advocacy of NCAFP and NCPeds, the company has ceased any further recovery efforts with this CCI edit denial and will be re-processing any claims for those providers who have submitted partial or full recovery payments. However, beginning August 24, 2022, the CCI edit for the code combination 90460/99401 will be effective. Please confirm that you are coding and billing your claims to accurately reflect these services.

Medicaid Publishes Results of Consumer and Provider Surveys

NC Medicaid recently published results of two surveys. One measures patient experiences with their health care while the other describes findings from the baseline assessment (Year 1) of the provider experience and satisfaction with the traditional NC Medicaid Direct system.

The Consumer Assessment of Healthcare Providers and Systems (CAHPS) is a patient experience survey that serves as a national standard for measuring and reporting respondents’ experiences with their health care. NC Medicaid administers the CAHPS surveys to adult and child Medicaid beneficiaries to understand the Medicaid beneficiary experience and inform improvements in care. The full report and a two-page summary are available. Some key results included:

• Adults rated both their overall health and mental or emotional health slightly better in 2021 than in 2019. However, when asked about their child’s mental or emotional health, ratings were slightly lower in 2021 than in 2019.

• Over 34 percent of adults reported not using non-emergency health care in the previous six months, up from 21 percent in 2019. But almost 85 percent indicated they usually or always received care right away when needed in 2021, up slightly from 2019.

• Over 41 percent of respondents reported their child did not use non-emergency healthcare in the previous six months as compared to just under 28 percent in 2019, verifying that there were gaps in well child visits and services during the pandemic. But nearly 96 percent reported their child usually or always received care right away, up slightly from 2019.

• Slightly more than 34 percent of adults reported being offered a telehealth visit instead of an in

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