APMA and CAC Engagement Coalition to Meet in Person With CMS

Updated October 7, 2024

On September 27, APMA responded to CMS on behalf of the CAC Engagement Coalition with a letter summarizing conversations between the Coalition and CMS from a previous June 5 meeting and meetings throughout the summer and recommended concrete opportunities for working collaboratively to address the group’s concerns regarding the development of local coverage and payment policy. CMS has indicated that it agreed with the majority of the recommendations included in our Principles for Sound Local Coverage Policies. APMA and the coalition, after a number of discussions over the summer, gathered consensus and indicated the greatest opportunities to improve the engagement of clinicians in local Medicare policy development, given feedback from CMS. APMA provided details on a number of these opportunities that you can read in the letter submitted. Among these were:

• increased engagement with CAC representatives, including regular, timely, and accessible CAC meetings and meaningful opportunity for CAC representatives to advise contractors and CMS on coverage and billing issues;
• transparency and use of objective criteria in the vetting and selection of individuals included on panels for CAC/evidentiary meetings, in addition to notifying CAC representatives as specified; and
• 60-day public notice period before policy changes are effectuated to LCD-referenced articles, including changes to covered CPT and ICD-10 codes, among other things.

In addition, and stemming from those summer discussions, on October 4, representatives from APMA net with CMS and MAC representatives to discuss opportunities to implement a new model for CAC meetings, dubbed the Provider Engagement Model (PEM). This model is planned to be used first in the NGS Jurisdiction. This model encourages greater communication among the CAC representatives, Contractor Medical Directors, and various specialty representatives and draws from the more effective elements from pre-existing traditional CAC meetings.

On June 5, APMA led a gathering of the Contractor Advisory Committee (CAC) Engagement Coalition of more than 20 organizations, including the AMA, in a hybrid meeting with CMS to address ongoing issues with the Local Coverage Determination development process. During the meeting, the coalition advocated that the new guidelines under 21st Century Cures are incorrectly interpreted to minimize the role of CAC representatives in Medicare Administrative Contractor (MAC) policy development; addressed a number of examples of current issues with the process; and highlighted a few solutions to resolve these issues, including by applying the coalition’s Principles for Sound Local Coverage Policies. CMS has agreed to additional meetings to discuss these potential solutions and has also offered to assist in MAC-specific issues. You can read more about the CAC process at www.apma.org/cacpiac.

Previously, on April 17, APMA hosted a gathering of the Contractor Advisory Committee (CAC) Engagement Coalition of more than 20 organizations to address ongoing issues with the Local Coverage process. Following multiple sessions with CMS, the coalition has opted to arrange a face-to-face meeting with CMS on May 17 to express its frustrations and concerns.

Repeatedly, the coalition has highlighted its collective concerns regarding the current implementation of local coverage policies, including concerns about the diminishing importance of CAC representatives' advisory roles, insufficient notice and comment procedures, procedural hurdles, and a lack of transparency. APMA anticipates that this forthcoming meeting will reflect an important step toward continuing to address our concerns.

For previous activities in this area, read this APMA Weekly Focus article.