AMDA's Position

Medical Director 501 F-Tag & Other F-Tag Revisions
F-Tags are the official government interpretations of the federal regulations. In 2006, the Medical Director F501 and F325 Nutritional Status F-Tags were enacted with substantive input from AMDA representatives. Subsequently in 2008 and 2009, the Pain Management F309, Feeding Assistants F373, Accidents F323, and Nutrition F325 were enacted. AMDA has taken a lead role in informing and education long term care physicians on these changes. AMDA also has updated its Synopsis of Federal Regulations in the Nursing Facility to reflect these changes.

Medicare Prescription Part D Drug Benefit
The Medicare Part D drug benefit has been the largest change to Medicare since its inception 40 years ago. AMDA has been a vocal, insistent voice for changes to the processes that can make it difficult to assure that long term care patients can receive the drugs they need. AMDA continues to monitor the program, with particular focus on issues related to formularies and drug utilization management policies. We continue to work with CMS to resolve problems when they arise.

New and Revised Nursing Facility CPT Codes
AMDA led the effort to redefine, update, and expand the nursing facility family of codes to better reflect the current realities of nursing facility patient care. The 2006 set of codes were the first changes to these billing codes in ten years. As noted below, AMDA continues to advocate for greater reimbursement for this code set through participation at the AMA/Specialty Society Relative Value Scale Update Committee (RUC) and written comments on CMS's annual update to the Medicare Fee Schedule.

Physician Payment
AMDA established the first discrete codes for nursing facility visits in 1990 and has been advocating for appropriate payment since then. The initiation of this set of codes improved payment by 10 to 20% for thousands of attending physicians, but Medicare cuts over the life of Resource Based Relative Value Scale (RBRVS) eroded them. Most recently, AMDA led the effort to revise the nursing facility family of codes effective in 2006. In 2007, AMDA successfully obtained higher physician work values for the codes. In particular, four of the Nursing Facility Services codes—the three initial visit codes 99304, 99305, 99306, and the 99307 for subsequent care—paid anywhere from 18 to 36% more in 2008 than in 2007. In 2009, these same codes received an approximately 5% increase over 2008 rates.

Professional Liability
Many long term care physicians continue to report problems with access to affordable insurance for their nursing home and medical director work. Many dedicated long term care physicians who have been involved in nursing facility care for their entire careers are dropped from their medical coverage when they renew their policy and list nursing homes as a site of service. Others are being asked to reduce their long term care commitments to patients or nursing facilities in order to retain insurance coverage. As a result, some physicians are dropping their long term care practices and limiting their services to the elderly. Medical directors of nursing facilities are the longest tenured staff at nursing facilities—averaging 10 years of service! As a member of the Health Coalition on Liability and Access (HCLA), AMDA works to pass meaningful medical liability reform. AMDA also works with the nursing home industry to explore other solutions specific to long term care.

Title VII Funding
AMDA has continually worked with its membership to support funding for Title VII of the Public Health Service Act, specifically its provisions on Geriatric Education Centers, Geriatric Training for Physicians, Dentists and Behavioral Health/Mental Health Professionals, and Geriatric Academic Career. Title VII is the only federal funding for programs that train providers for underserved populations. AMDA’s members have sent letters to Congress making them aware of how important funding for these types of education programs is to the future of geriatric care. The consequences of no funding could result in an inadequate workforce for the growing number of elderly in the U.S. AMDA also passed a resolution supporting the reinstatement for funding in resolution C06 entitled "Graduate Education Centers", which was introduced by the Missouri Association for Long Term Care Physicians and the Pennsylvania Medical Directors Association. The resolution explained that geriatric education programs authorized under Title VII have educated more than 425,000 healthcare professionals and data indicates there will be severe shortages of trained professional in geriatrics to meet the exploding need as 78 million baby boomers begin to turn 65.