MASHBURN, MARTHA--AR

Regarding Section 5501: Expanding Access to Primary Care Services and General Surgery Services, it seems the list of codes for primary care services eligible for primary care incentive payments are not broad enough. Preventive services are just as much primary care services as office visits and inclusion of these services could incent primary care physicians to provide and order these. Actually, they are certainly services that are generally considered Primary Care services. By preventive services, I am including the immunization administration codes as well as the HCPCS/CPT codes for services listed on the "Quick Reference Information for Medicare Preventive Services" which is published by CMS. By including these in the list of services eligible for incentive payments, it could help Internal Medicine physicians meet the 60% requirement. Even with the addition of these, however, it will still be difficult for Internal Medicine physicians to meet the requirements as their patients often have more complicated conditions, requiring more extension services and testing. Another suggestion would be to reduce the 60% requirement to 50% or 55%, at least for Internal Medicine. Otherwise, there won't be much incentive for these physicians to see more Medicare patients. We already have a shortage of physicians within this specialty and many, if not most, have already limited their Medicare patient population and are no longer accepting new Medicare patients. Something needs to be done to increase the incentive for this specialty. Please consider these suggestions in determining the final rule for this proposal.