PMDA Public Policy

Advance Care Planning Codes

2015 CMS Includes Codes for ACP

  • EM Codes = 99497 and 99498
  • Status = I (Inactive)

July 8, 2016 CMS Proposes Inclusion in Final Physician Fee Schedule

  • Status = A (Active)
  • Medicare carriers would have to develop local policy
  • Could be billed along with EM visit codes
  • Applicable to the nursing facility setting

PMDA ACP Position

  • PMDA supports inclusion of EM codes 99497-8 into the physician fee schedule as active codes.
  • ACP is a crucial component of quality medical care and should be reimbursed. ACP is a part of patient centered care.
  • PMDA urges carriers to adopt coverage policies for these codes.

PMDA ACP Actions

  • Monitoring for final CMS PFS
  • Planned education for members
CMS Proposed Reforms of Nursing Facility Regulations

CMS NF Regulation Reform

  • July 2015, CMS releases proposed regulatory reforms for NF that would update the 1987 OBRA based regulations. View the proposal.
  • AMDA & PMDA both submitted comments
  • Infection control & antimicrobial stewardship changes
    1. Infection Control & Prevention Officer (ICPO)
      • “Major responsibility”
      • FTE requirement variable based on facility
      • FTE estimates = 15% for 100 bed facility
    2. Antimicrobial Stewardship Program would be required
  • Requirement for face to face visit before transferring a resident
  • Would allow dieticians to write orders for therapeutic diets

PMDA Regulatory Reform Position

  • PMDA submitted detailed comments to CMS. Read the comments.
  • Opposed the requirement for a FTF visit prior to transferring a resident
  • Opposed ability of dieticians to write orders independent of physicians

PMDA Regulatory Reform Actions

  • Planned education for members
Physician Workforce

PMDA Members Note Challenges Recruiting Physicians

  • Particularly LTC and in rural areas

PMDA Workforce Position

  • No position established yet

PMDA Workforce Actions

  • Work group formation
  • Literature scan to define scope and identify strategies
  • Outreach to Leading Age and AGS
Additional Resources

June 2014 – PA Dept of Health FAQ on ACT 122 – related to use of outside laboratories in LTC


Pennsylvania Medical Directors Association · 777 East Park Drive, P.O. Box 8820, Harrisburg, PA 17105-8820
Phone: 717-558-7868 · Fax: 717-558-7841 · Email:
Director & Administrator Login · Privacy Policy · Terms of Use
Copyright © 2017, Pennsylvania Medical Directors Association. All rights reserved.