feedback on Navigation Reimbursement Policy

 Are you looking for an opportunity to share feedback about the recently introduced Navigation Reimbursement?! NOW IS THE TIME! The AONN+ Policy and Advocacy Committee would like to invite and support you in sharing your expert opinions with the Centers for Medicare and Medicaid (CMS). CMS is accepting feedback until Sept 9, 2024 about the Physician Fee Schedule for CY2025. Reimbursement for Principal Illness Navigation was included for the first time in the Physician Fee Schedule for CY2024.***See below: your patients are depending on you. Indications that your feedback is needed:

• Your program is currently utilizing these new billing codes and you have examples of how this is working well, or you have recommendations for improvements
• Your program has elected not to utilize these codes, but would reconsider if changes were made
• You have data or experiences to share regarding CMS' definition of which patients qualify for Principal Illness Navigation services (SEE Critical Definitions attached to this email),
• You work with other navigators when providing care for patients and would be impacted by the current CMS stipulation that only one navigator can bill for patient care in a given month,
• You are a navigator for a community-based organization and would like to use these billing codes in conjunction with a provider's office,
• You have ideas for improving utilization of these billing codes in rural settings,
• You have experience consenting patients for navigation services, or feedback about how consenting for navigation services would work in your program

 What does your feedback need to look like?

• You can share as little or as much as you would like. As navigators we are trained to look for ways our patients can be impacted by changes in policy. Your voices and your experiences are valuable to share with our policymakers who do not work directly with patients. Your feedback will be more powerful if you can share specific experiences or data.

 How do I submit feedback?

• Go to www.federalregister.gov/documents/2024/0...e-schedule-and-other
• Click on "Submit a Formal Comment"
• Submit your Comment, email address, and who you are (individual, organization, or anonymous)

 Examples of feedback submitted in September 2023 for FY2024:Example # 1: Payment Reduction for Physical Therapy

• I am writing to oppose CMS payment reductions for physical therapy services. The agency’s proposed 2% reduction to the 2025 conversion factor fails to offer clinicians support to serve the growing Medicare population. These cuts jeopardize my practice and I fear I won’t be able to provide skilled therapy to Medicare patients if these cumulative reductions don’t stop.

Example # 2: Activating Coding and Payment for Interprofessional Consultation

• I fully support CMS’ proposal to establish a reimbursement mechanism for behavioral health clinicians engaging in interprofessional consultations for the treatment of their patients. Psychologists are increasingly being called upon to consult on other providers’ patients as a way of extending the workforce. This proposal acknowledges the reality of modern behavioral health treatment and I urge CMS to finalize it.

Example # 3: Community health integration (CHI) services, principal illness navigation (PIN) services, and social determinants of health (SDOH) risk assessment

• Social workers play an essential role in the coordination and care between the member, their healthcare system, their community and their family. These are also critical components in CHI, PIN and SDOH. Therefore, one person is doing the work in all of these different areas it is difficult to determine how to time-track and record their time and meet the requirements of all the services that they are providing as a part of PCP groups. Most of this work could also be considered a part of CCM/PCM/CCCM therefore it is more beneficial

 Critical Definitions from the CMS guidelines are attached to this email***Your experience as a patient navigator matters and your feedback on this important policy is crucial!! We sincerely hope you will take the time to submit a response by September 9, 2024. Your patients need your advocacy and support! They depend on YOU!  Jamie Callahan, BSN-RN, OCN, CBCN (she/her/hers)Oncology Nurse NavigatorAONN+ Policy and Advocacy Committee Chair