{"title":"AGS 政策更新","authors":"Donna M. Fick, PhD, GCNS-BC, AGSF, FGSA, FAAN","doi":"10.3928/00989134-20240416-08","DOIUrl":null,"url":null,"abstract":"<h2>Introduction</h2><p>I am #AGSProud of the advocacy work that the American Geriatrics Society (AGS) does on behalf of older adults and the geriatrics health professionals who serve them. One reason why our advocacy is so impactful is that AGS is able to draw on the expertise of its members to inform our comment letters. AGS remains steadfast in its commitment to advocating for the rights and well-being of older adults, emphasizing equal protection and treatment for all. In this column, I have summarized several of our AGS comment letters with the goal of providing a glimpse into our ongoing efforts to shape public policy with the goal of improving the lives of all older adults. From addressing staffing standards in long-term care facilities to recommending the reconsideration of using revised criteria for the diagnosis and staging of Alzheimer's disease to inform clinical care, each letter reflects our commitment to advocating for policies that support all of us as we age.</p><h2>Comment Letter on Minimum Staffing Standards for Long-Term Care Facilities</h2><p>In November 2023, AGS submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to its proposal to revise minimum staffing standards for long-term care facilities (AGS, 2023c). In our letter, we noted our appreciation for CMS' proposal to set minimum staffing standards, which we believe are an important, incremental first step to ensure safe, reliable, and quality nursing home care. Our letter offers comments and recommendations on several CMS proposals, including proposed minimum nursing staffing standards, hardship exemptions, RN onsite requirement, facility assessment requirements, and implementation deadlines.</p><h2>Comment Letter on Ways and Means Committee Request Around Rural Health Care</h2><p>In October 2023, AGS submitted recommendations in response to a request from the House Committee on Ways and Means on a legislative framework for improving access to health care in rural and underserved areas (Smith, 2023). In our letter (AGS, 2023b), AGS offered support and feedback as the Committee looks to identify solutions to reshape our nation's health care system and improve our nation's health for future generations. We asked the Committee to consider several potential solutions to increasing access to primary care clinicians, including geriatricians. These solutions include restoration of the primary care bonus payment that was included in the Affordable Care Act, opportunities for loan repayment and forgiveness for those entering geriatrics, support for legislation focused on enhancing the health care workforce, and other improvements, such as access to telehealth services and Medicare payment system reform.</p><h2>Comments on the 2024 Medicare Physician Fee Schedule</h2><p>In September 2023, AGS submitted extensive comments in response to the CMS Calendar Year 2024 proposed rule updating the Medicare Physician Fee Schedule (PFS) and Quality Payment Program (AGS, 2023a). In our letter, we urged CMS to finalize the proposed payment for caregiver training services and the implementation of the complexity add-on code (G2211) effective January 1, 2024. We also urged CMS to finalize payment for Community Health Integration Services, Social Determinants of Health Risk Assessment, and Principal Illness Navigation Services. We were also pleased to see that CMS proposed to extend the additional payment for COVID-19 vaccines furnished in the home and expand its application to other Part B preventive vaccines. AGS commented on several telehealth provisions, including audio-only services, which we urged CMS to finalize the proposed coverage and payment. We supported CMS' delay of its split (or shared) visits policy and recommended that CMS extend its shared visit policy to certain home visits. A final rule was issued in early November 2023 and took effect on January 1, 2024. AGS was pleased to see that CMS accepted many of our recommendations, including implementing the add-on code for visit complexity and payment for vaccine administration in the home, among other proposals. A summary of the final rule can be found at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule-medicare-shared-savings-program.</p><h2>Comments on Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup</h2><p>In November 2023, AGS (2023d) submitted comments on the third draft of the Revised Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup (Alzheimer's Association, 2023), an update of the 2018 National Institute on Aging–Alzheimer's Association Revised Clinical Guidelines for Alzheimer's Disease (Alzheimer's Association, n.d.). Among other items, we recommended that the Alzheimer's Association Workgroup carefully reconsider whether the available evidence warrants moving from a research framework to the proposed use of the revised criteria to inform clinical care, including the proposed shift to use biomarkers to diagnose Alzheimer's disease. Given that practitioners, patients, and society have not been sufficiently prepared for a shift in Alzheimer's disease diagnosis, and there is no current evidence to support use of the revised criteria in routine clinical care, AGS remains concerned that this proposed expansion will place many older and multimorbid people at risk of overdiagnosis, which in turn could lead to high potential of harm and initiation of treatments with as yet unproven clinical benefit, particularly in an asymptomatic population. Our comment letter submitted earlier in 2023 on the initial draft of the revised criteria can be found at https://bit.ly/3TyhGou.</p><p>I encourage you to stay informed about AGS's ongoing policy work by visiting the Where We Stand section of the AGS website ( https://www.americangeriatrics.org/where-we-stand). In addition, the Health in Aging Advocacy Center provides a platform for you to take action on various issues impacting the health and well-being of older adults and the geriatrics health care professionals who care for them.</p><p><strong>Donna M. Fick, PhD, GCNS-BC, AGSF,</strong></p><p><strong>FGSA, FAAN</strong></p><p>President, American Geriatrics Society</p><p></p><ul><li><span><span>Alzheimer's Association</span>. (<span>n.d.</span>). <span><i>Diagnostic criteria & guidelines</i></span>. https://www.alz.org/research/for_researchers/diagnostic-criteria-guidelines?_gl=1*1to8v02*_ga*MjExNjIyNTczNS4xNjc4ODI3NTQ2*_ga_9JTEWVX24V*MTY5MjIwODk2NC4yMC4wLjE2OTIyMDg5NjQuNjAuMC4w&_ga=2.47168103.1792500547.1692030933-2116225735.1678827546 </span><p></p>> <span>Google Scholar</span></li><li><span><span>Alzheimer's Association</span>. (<span>2023</span>, <span>October</span> <span>9</span>). <span><i>Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup</i></span>. https://alz.org/media/Documents/scientific-conferences/Clinical-Criteria-for-Staging-and-Diagnosis-for-Public-Comment-Draft-2.pdf?_gl=1*oyafaj*_ga*MTI4MjY1OTEyOC4xNjk3NDc4ODk1*_ga_9JTEWVX24V*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w*_ga_QSFTKCEH7C*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023a</span>, <span>September</span> <span>11</span>). <span><i>Re: Medicare and Medicaid Programs; CY 2024 payment policies under the Physician Fee Schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; Medicare Advantage; Medicare and Medicaid provider and supplier enrollment policies; basic health program (CMS-1784-P)</i></span> [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comment%20CY%202024%20MPFS%20and%20QPP%20Proposed%20Rule%20FINAL%20%289%2011%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023b</span>, <span>October</span> <span>5</span>). <span><i>Re: House Committee on Ways and Means request for input on improving access to health care in rural and underserved areas</i></span>. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Letter%20to%20Ways%20and%20Means%20Committee%20on%20Rural%20Health%20Care%20%2810%205%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. <span>2023c</span>, <span>November</span> <span>6</span>). <span><i>Re: Medicare and Medicaid programs; minimum staffing standards for long-term care facilities and Medicaid institutional payment transparency reporting (CMS-3442-P)</i></span> [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20LTC%20Minimum%20Staff%20Comment%20Letter%2011%206%2023%20FINAL.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023d</span>, <span>November</span> <span>16</span>). <span><i>American Geriatrics Society response – Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup</i></span>. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comments%20on%20Revised%20Criteria%20for%20Diagnosis%20and%20Staging%20of%20AD%20%2811%2016%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>Smith J</span>. (<span>2023</span>, <span>September</span> <span>7</span>). <span><i>Request for information: Improving access to health care in rural and underserved areas</i></span>[Letter]. <span>U.S. House of Representatives Committee on Ways and Means</span>. https://waysandmeans.house.gov/wp-content/uploads/2023/09/WM-Rural-Health-Care-RFI.pdf </span><p></p>> <span>Google Scholar</span></li></ul>","PeriodicalId":15848,"journal":{"name":"Journal of gerontological nursing","volume":null,"pages":null},"PeriodicalIF":1.1000,"publicationDate":"2024-05-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"0","resultStr":"{\"title\":\"AGS Policy Update\",\"authors\":\"Donna M. Fick, PhD, GCNS-BC, AGSF, FGSA, FAAN\",\"doi\":\"10.3928/00989134-20240416-08\",\"DOIUrl\":null,\"url\":null,\"abstract\":\"<h2>Introduction</h2><p>I am #AGSProud of the advocacy work that the American Geriatrics Society (AGS) does on behalf of older adults and the geriatrics health professionals who serve them. One reason why our advocacy is so impactful is that AGS is able to draw on the expertise of its members to inform our comment letters. AGS remains steadfast in its commitment to advocating for the rights and well-being of older adults, emphasizing equal protection and treatment for all. In this column, I have summarized several of our AGS comment letters with the goal of providing a glimpse into our ongoing efforts to shape public policy with the goal of improving the lives of all older adults. From addressing staffing standards in long-term care facilities to recommending the reconsideration of using revised criteria for the diagnosis and staging of Alzheimer's disease to inform clinical care, each letter reflects our commitment to advocating for policies that support all of us as we age.</p><h2>Comment Letter on Minimum Staffing Standards for Long-Term Care Facilities</h2><p>In November 2023, AGS submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to its proposal to revise minimum staffing standards for long-term care facilities (AGS, 2023c). In our letter, we noted our appreciation for CMS' proposal to set minimum staffing standards, which we believe are an important, incremental first step to ensure safe, reliable, and quality nursing home care. Our letter offers comments and recommendations on several CMS proposals, including proposed minimum nursing staffing standards, hardship exemptions, RN onsite requirement, facility assessment requirements, and implementation deadlines.</p><h2>Comment Letter on Ways and Means Committee Request Around Rural Health Care</h2><p>In October 2023, AGS submitted recommendations in response to a request from the House Committee on Ways and Means on a legislative framework for improving access to health care in rural and underserved areas (Smith, 2023). In our letter (AGS, 2023b), AGS offered support and feedback as the Committee looks to identify solutions to reshape our nation's health care system and improve our nation's health for future generations. We asked the Committee to consider several potential solutions to increasing access to primary care clinicians, including geriatricians. These solutions include restoration of the primary care bonus payment that was included in the Affordable Care Act, opportunities for loan repayment and forgiveness for those entering geriatrics, support for legislation focused on enhancing the health care workforce, and other improvements, such as access to telehealth services and Medicare payment system reform.</p><h2>Comments on the 2024 Medicare Physician Fee Schedule</h2><p>In September 2023, AGS submitted extensive comments in response to the CMS Calendar Year 2024 proposed rule updating the Medicare Physician Fee Schedule (PFS) and Quality Payment Program (AGS, 2023a). In our letter, we urged CMS to finalize the proposed payment for caregiver training services and the implementation of the complexity add-on code (G2211) effective January 1, 2024. We also urged CMS to finalize payment for Community Health Integration Services, Social Determinants of Health Risk Assessment, and Principal Illness Navigation Services. We were also pleased to see that CMS proposed to extend the additional payment for COVID-19 vaccines furnished in the home and expand its application to other Part B preventive vaccines. AGS commented on several telehealth provisions, including audio-only services, which we urged CMS to finalize the proposed coverage and payment. We supported CMS' delay of its split (or shared) visits policy and recommended that CMS extend its shared visit policy to certain home visits. A final rule was issued in early November 2023 and took effect on January 1, 2024. AGS was pleased to see that CMS accepted many of our recommendations, including implementing the add-on code for visit complexity and payment for vaccine administration in the home, among other proposals. A summary of the final rule can be found at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule-medicare-shared-savings-program.</p><h2>Comments on Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup</h2><p>In November 2023, AGS (2023d) submitted comments on the third draft of the Revised Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup (Alzheimer's Association, 2023), an update of the 2018 National Institute on Aging–Alzheimer's Association Revised Clinical Guidelines for Alzheimer's Disease (Alzheimer's Association, n.d.). Among other items, we recommended that the Alzheimer's Association Workgroup carefully reconsider whether the available evidence warrants moving from a research framework to the proposed use of the revised criteria to inform clinical care, including the proposed shift to use biomarkers to diagnose Alzheimer's disease. Given that practitioners, patients, and society have not been sufficiently prepared for a shift in Alzheimer's disease diagnosis, and there is no current evidence to support use of the revised criteria in routine clinical care, AGS remains concerned that this proposed expansion will place many older and multimorbid people at risk of overdiagnosis, which in turn could lead to high potential of harm and initiation of treatments with as yet unproven clinical benefit, particularly in an asymptomatic population. Our comment letter submitted earlier in 2023 on the initial draft of the revised criteria can be found at https://bit.ly/3TyhGou.</p><p>I encourage you to stay informed about AGS's ongoing policy work by visiting the Where We Stand section of the AGS website ( https://www.americangeriatrics.org/where-we-stand). In addition, the Health in Aging Advocacy Center provides a platform for you to take action on various issues impacting the health and well-being of older adults and the geriatrics health care professionals who care for them.</p><p><strong>Donna M. Fick, PhD, GCNS-BC, AGSF,</strong></p><p><strong>FGSA, FAAN</strong></p><p>President, American Geriatrics Society</p><p></p><ul><li><span><span>Alzheimer's Association</span>. (<span>n.d.</span>). <span><i>Diagnostic criteria & guidelines</i></span>. https://www.alz.org/research/for_researchers/diagnostic-criteria-guidelines?_gl=1*1to8v02*_ga*MjExNjIyNTczNS4xNjc4ODI3NTQ2*_ga_9JTEWVX24V*MTY5MjIwODk2NC4yMC4wLjE2OTIyMDg5NjQuNjAuMC4w&_ga=2.47168103.1792500547.1692030933-2116225735.1678827546 </span><p></p>> <span>Google Scholar</span></li><li><span><span>Alzheimer's Association</span>. (<span>2023</span>, <span>October</span> <span>9</span>). <span><i>Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup</i></span>. https://alz.org/media/Documents/scientific-conferences/Clinical-Criteria-for-Staging-and-Diagnosis-for-Public-Comment-Draft-2.pdf?_gl=1*oyafaj*_ga*MTI4MjY1OTEyOC4xNjk3NDc4ODk1*_ga_9JTEWVX24V*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w*_ga_QSFTKCEH7C*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023a</span>, <span>September</span> <span>11</span>). <span><i>Re: Medicare and Medicaid Programs; CY 2024 payment policies under the Physician Fee Schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; Medicare Advantage; Medicare and Medicaid provider and supplier enrollment policies; basic health program (CMS-1784-P)</i></span> [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comment%20CY%202024%20MPFS%20and%20QPP%20Proposed%20Rule%20FINAL%20%289%2011%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023b</span>, <span>October</span> <span>5</span>). <span><i>Re: House Committee on Ways and Means request for input on improving access to health care in rural and underserved areas</i></span>. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Letter%20to%20Ways%20and%20Means%20Committee%20on%20Rural%20Health%20Care%20%2810%205%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. <span>2023c</span>, <span>November</span> <span>6</span>). <span><i>Re: Medicare and Medicaid programs; minimum staffing standards for long-term care facilities and Medicaid institutional payment transparency reporting (CMS-3442-P)</i></span> [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20LTC%20Minimum%20Staff%20Comment%20Letter%2011%206%2023%20FINAL.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>American Geriatrics Society</span>. (<span>2023d</span>, <span>November</span> <span>16</span>). <span><i>American Geriatrics Society response – Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup</i></span>. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comments%20on%20Revised%20Criteria%20for%20Diagnosis%20and%20Staging%20of%20AD%20%2811%2016%2023%29.pdf </span><p></p>> <span>Google Scholar</span></li><li><span><span>Smith J</span>. (<span>2023</span>, <span>September</span> <span>7</span>). <span><i>Request for information: Improving access to health care in rural and underserved areas</i></span>[Letter]. <span>U.S. House of Representatives Committee on Ways and Means</span>. https://waysandmeans.house.gov/wp-content/uploads/2023/09/WM-Rural-Health-Care-RFI.pdf </span><p></p>> <span>Google Scholar</span></li></ul>\",\"PeriodicalId\":15848,\"journal\":{\"name\":\"Journal of gerontological nursing\",\"volume\":null,\"pages\":null},\"PeriodicalIF\":1.1000,\"publicationDate\":\"2024-05-01\",\"publicationTypes\":\"Journal Article\",\"fieldsOfStudy\":null,\"isOpenAccess\":false,\"openAccessPdf\":\"\",\"citationCount\":\"0\",\"resultStr\":null,\"platform\":\"Semanticscholar\",\"paperid\":null,\"PeriodicalName\":\"Journal of gerontological nursing\",\"FirstCategoryId\":\"3\",\"ListUrlMain\":\"https://doi.org/10.3928/00989134-20240416-08\",\"RegionNum\":4,\"RegionCategory\":\"医学\",\"ArticlePicture\":[],\"TitleCN\":null,\"AbstractTextCN\":null,\"PMCID\":null,\"EPubDate\":\"\",\"PubModel\":\"\",\"JCR\":\"Q4\",\"JCRName\":\"GERIATRICS & GERONTOLOGY\",\"Score\":null,\"Total\":0}","platform":"Semanticscholar","paperid":null,"PeriodicalName":"Journal of gerontological nursing","FirstCategoryId":"3","ListUrlMain":"https://doi.org/10.3928/00989134-20240416-08","RegionNum":4,"RegionCategory":"医学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"Q4","JCRName":"GERIATRICS & GERONTOLOGY","Score":null,"Total":0}
引用次数: 0
摘要
除其他事项外，我们还建议阿尔茨海默氏症协会工作组仔细重新考虑现有证据是否支持从研究框架转向使用修订标准为临床护理提供信息的提议，包括使用生物标记物诊断阿尔茨海默氏症的提议转变。鉴于从业人员、患者和社会尚未为阿尔茨海默病诊断的转变做好充分准备，而且目前也没有证据支持在常规临床护理中使用修订后的标准，因此 AGS 仍然担心这一拟议的扩展将使许多老年人和多病人群面临过度诊断的风险，这反过来又可能导致高潜在危害和启动尚未证实临床益处的治疗，尤其是在无症状人群中。我们在 2023 年早些时候提交的关于修订标准初稿的评论信可在 https://bit.ly/3TyhGou.I 上找到，我们鼓励您访问 AGS 网站的 "我们的立场 "部分（https://www.americangeriatrics.org/where-we-stand），随时了解 AGS 正在开展的政策工作。此外，"老龄健康宣传中心 "为您提供了一个平台，使您能够就影响老年人健康和福祉的各种问题以及为他们提供护理的老年医学医疗保健专业人员采取行动。Donna M. Fick, PhD, GCNS-BC, AGSF,FGSA, FAAN美国老年医学会阿尔茨海默氏症协会主席。(n.d.).https://www.alz.org/research/for_researchers/diagnostic-criteria-guidelines?_gl=1*1to8v02*_ga*MjExNjIyNTczNS4xNjc4ODI3NTQ2*_ga_9JTEWVX24V*MTY5MjIwODk2NC4yMC4wLjE2OTIyMDg5NjQuNjAuMC4w&_ga=2.47168103.1792500547.1692030933-2116225735.1678827546 > Google Scholar阿尔茨海默氏症协会。(2023 年 10 月 9 日）。阿尔茨海默病诊断和分期的修订标准：阿尔茨海默病协会工作组。https://alz.org/media/Documents/scientific-conferences/Clinical-Criteria-for-Staging-and-Diagnosis-for-Public-Comment-Draft-2.pdf?_gl=1*oyafaj*_ga*MTI4MjY1OTEyOC4xNjk3NDc4ODk1*_ga_9JTEWVX24V*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w*_ga_QSFTKCEH7C*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w >；谷歌学术美国老年医学会。(2023a, September 11).Re：联邦医疗保险和医疗补助计划；2024 财年医生收费表下的支付政策以及 B 部分支付和承保政策的其他变更；联邦医疗保险共享储蓄计划要求；联邦医疗保险优势；联邦医疗保险和医疗补助提供商和供应商注册政策；基本健康计划（CMS-1784-P）[信]。https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comment%20CY%202024%20MPFS%20and%20QPP%20Proposed%20Rule%20FINAL%20%289%2011%2023%29.pdf > Google Scholar美国老年医学会。(2023b, October 5).Re：https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Letter%20to%20Ways%20and%20Means%20Committee%20on%20Rural%20Health%20Care%20%2810%205%2023%29.pdf > Google ScholarAmerican Geriatrics Society.2023c，11 月 6 日）。Re：https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20LTC%20Minimum%20Staff%20Comment%20Letter%2011%206%2023%20FINAL.pdf > Google ScholarAmerican Geriatrics Society.(2023d, November 16).美国老年医学会回应--阿尔茨海默病诊断和分期标准修订版：https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comments%20on%20Revised%20Criteria%20for%20Diagnosis%20and%20Staging%20of%20AD%20%2811%2016%2023%29.pdf > Google ScholarSmith J. (2023 年 9 月 7 日)。请求提供信息：改善农村和服务不足地区的医疗服务[信]。https://waysandmeans.house.gov/wp-content/uploads/2023/09/WM-Rural-Health-Care-RFI.pdf > Google Scholar
I am #AGSProud of the advocacy work that the American Geriatrics Society (AGS) does on behalf of older adults and the geriatrics health professionals who serve them. One reason why our advocacy is so impactful is that AGS is able to draw on the expertise of its members to inform our comment letters. AGS remains steadfast in its commitment to advocating for the rights and well-being of older adults, emphasizing equal protection and treatment for all. In this column, I have summarized several of our AGS comment letters with the goal of providing a glimpse into our ongoing efforts to shape public policy with the goal of improving the lives of all older adults. From addressing staffing standards in long-term care facilities to recommending the reconsideration of using revised criteria for the diagnosis and staging of Alzheimer's disease to inform clinical care, each letter reflects our commitment to advocating for policies that support all of us as we age.
Comment Letter on Minimum Staffing Standards for Long-Term Care Facilities
In November 2023, AGS submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to its proposal to revise minimum staffing standards for long-term care facilities (AGS, 2023c). In our letter, we noted our appreciation for CMS' proposal to set minimum staffing standards, which we believe are an important, incremental first step to ensure safe, reliable, and quality nursing home care. Our letter offers comments and recommendations on several CMS proposals, including proposed minimum nursing staffing standards, hardship exemptions, RN onsite requirement, facility assessment requirements, and implementation deadlines.
Comment Letter on Ways and Means Committee Request Around Rural Health Care
In October 2023, AGS submitted recommendations in response to a request from the House Committee on Ways and Means on a legislative framework for improving access to health care in rural and underserved areas (Smith, 2023). In our letter (AGS, 2023b), AGS offered support and feedback as the Committee looks to identify solutions to reshape our nation's health care system and improve our nation's health for future generations. We asked the Committee to consider several potential solutions to increasing access to primary care clinicians, including geriatricians. These solutions include restoration of the primary care bonus payment that was included in the Affordable Care Act, opportunities for loan repayment and forgiveness for those entering geriatrics, support for legislation focused on enhancing the health care workforce, and other improvements, such as access to telehealth services and Medicare payment system reform.
Comments on the 2024 Medicare Physician Fee Schedule
In September 2023, AGS submitted extensive comments in response to the CMS Calendar Year 2024 proposed rule updating the Medicare Physician Fee Schedule (PFS) and Quality Payment Program (AGS, 2023a). In our letter, we urged CMS to finalize the proposed payment for caregiver training services and the implementation of the complexity add-on code (G2211) effective January 1, 2024. We also urged CMS to finalize payment for Community Health Integration Services, Social Determinants of Health Risk Assessment, and Principal Illness Navigation Services. We were also pleased to see that CMS proposed to extend the additional payment for COVID-19 vaccines furnished in the home and expand its application to other Part B preventive vaccines. AGS commented on several telehealth provisions, including audio-only services, which we urged CMS to finalize the proposed coverage and payment. We supported CMS' delay of its split (or shared) visits policy and recommended that CMS extend its shared visit policy to certain home visits. A final rule was issued in early November 2023 and took effect on January 1, 2024. AGS was pleased to see that CMS accepted many of our recommendations, including implementing the add-on code for visit complexity and payment for vaccine administration in the home, among other proposals. A summary of the final rule can be found at https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2024-medicare-physician-fee-schedule-final-rule-medicare-shared-savings-program.
Comments on Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup
In November 2023, AGS (2023d) submitted comments on the third draft of the Revised Criteria for Diagnosis and Staging of Alzheimer's Disease: Alzheimer's Association Workgroup (Alzheimer's Association, 2023), an update of the 2018 National Institute on Aging–Alzheimer's Association Revised Clinical Guidelines for Alzheimer's Disease (Alzheimer's Association, n.d.). Among other items, we recommended that the Alzheimer's Association Workgroup carefully reconsider whether the available evidence warrants moving from a research framework to the proposed use of the revised criteria to inform clinical care, including the proposed shift to use biomarkers to diagnose Alzheimer's disease. Given that practitioners, patients, and society have not been sufficiently prepared for a shift in Alzheimer's disease diagnosis, and there is no current evidence to support use of the revised criteria in routine clinical care, AGS remains concerned that this proposed expansion will place many older and multimorbid people at risk of overdiagnosis, which in turn could lead to high potential of harm and initiation of treatments with as yet unproven clinical benefit, particularly in an asymptomatic population. Our comment letter submitted earlier in 2023 on the initial draft of the revised criteria can be found at https://bit.ly/3TyhGou.
I encourage you to stay informed about AGS's ongoing policy work by visiting the Where We Stand section of the AGS website ( https://www.americangeriatrics.org/where-we-stand). In addition, the Health in Aging Advocacy Center provides a platform for you to take action on various issues impacting the health and well-being of older adults and the geriatrics health care professionals who care for them.
Alzheimer's Association. (2023, October9). Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup. https://alz.org/media/Documents/scientific-conferences/Clinical-Criteria-for-Staging-and-Diagnosis-for-Public-Comment-Draft-2.pdf?_gl=1*oyafaj*_ga*MTI4MjY1OTEyOC4xNjk3NDc4ODk1*_ga_9JTEWVX24V*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w*_ga_QSFTKCEH7C*MTcwMDE3MDAwNC4yOS4xLjE3MDAxNzAyMTMuNjAuMC4w > Google Scholar
American Geriatrics Society. (2023a, September11). Re: Medicare and Medicaid Programs; CY 2024 payment policies under the Physician Fee Schedule and other changes to Part B payment and coverage policies; Medicare Shared Savings Program requirements; Medicare Advantage; Medicare and Medicaid provider and supplier enrollment policies; basic health program (CMS-1784-P) [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comment%20CY%202024%20MPFS%20and%20QPP%20Proposed%20Rule%20FINAL%20%289%2011%2023%29.pdf > Google Scholar
American Geriatrics Society. (2023b, October5). Re: House Committee on Ways and Means request for input on improving access to health care in rural and underserved areas. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Letter%20to%20Ways%20and%20Means%20Committee%20on%20Rural%20Health%20Care%20%2810%205%2023%29.pdf > Google Scholar
American Geriatrics Society. 2023c, November6). Re: Medicare and Medicaid programs; minimum staffing standards for long-term care facilities and Medicaid institutional payment transparency reporting (CMS-3442-P) [Letter]. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20LTC%20Minimum%20Staff%20Comment%20Letter%2011%206%2023%20FINAL.pdf > Google Scholar
American Geriatrics Society. (2023d, November16). American Geriatrics Society response – Revised criteria for diagnosis and staging of Alzheimer's disease: Alzheimer's Association Workgroup. https://www.americangeriatrics.org/sites/default/files/inline-files/AGS%20Comments%20on%20Revised%20Criteria%20for%20Diagnosis%20and%20Staging%20of%20AD%20%2811%2016%2023%29.pdf > Google Scholar
Smith J. (2023, September7). Request for information: Improving access to health care in rural and underserved areas[Letter]. U.S. House of Representatives Committee on Ways and Means. https://waysandmeans.house.gov/wp-content/uploads/2023/09/WM-Rural-Health-Care-RFI.pdf > Google Scholar
期刊介绍：
The Journal of Gerontological Nursing is a monthly, peer-reviewed journal publishing clinically relevant original articles on the practice of gerontological nursing across the continuum of care in a variety of health care settings, for more than 40 years.
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