Comment on CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment (Staging)
Take action now to protect peer support services under Medicare!
The Centers for Medicare and Medicaid Services (CMS) is seeking public comment on the 2024 Physician Fee Schedule rule, which determines what mental health and substance services are covered in Medicare. The proposed rule, issued this summer, includes several proposals related to Peer Support Specialist services. We are urging CMS to clarify the role of Peer Support Specialist to ensure fidelity to the profession and distinguish it from other services.
We need your help to make sure that CMS hears from peer specialists and allies to the peer support profession on this important issue. Please take a few minutes to submit a comment on the proposed rule. You can find a template for your comment to the right on this page.
In your comment, please explain why you care about making sure that Peer Support Specialists are able to practice the competencies and values unique to the profession, as outlined in SAMHSA’s Core Competencies and the N.A.P.S. National Practice Guidelines. You can also add a few sentences about who you are and why you are concerned about these issues.
Please note that when you submit a regulatory comment, your entire comment submission is accessible public record, including any personal information added. If you are not comfortable sharing personal information, you can omit it from your comment.
Thank you for taking the time to help us ensure that Peer Support Specialists are able to fulfill the duties of their profession under the Medicare program and that beneficiaries of Medicare who receive peer support services can effectively engage with this evidence-based practice in alignment with its intended design and research.
Medicare and Medicaid Programs: CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment, etc.
Regulations.gov Document ID
CMS-2023-0121-1282 (download PDF)
Agency
CMS
Comment Period
Aug 7, 2023 to Sep 11, 2023
View the terms of participation and privacy notice for Regulations.gov.
Please feel free to copy and paste the suggested language below into the comment form at the link. You are free to edit however you would like and encouraged to add your own language about why this matters to you.
Suggested language:
I appreciate the opportunity to comment on the proposed 2024 Medicare Physician Fee Schedule, specifically in relation to Peer Support Specialists (PSS) and Principal Illness Navigation (PIN) services.
My key concern is the misalignment of some of the PIN services with PSS standards and values. PSS would be required to operate outside of the scope of their training, certification, and code of ethics which would increase role ambiguity and dissatisfaction among PSS professionals. The current list of PIN services would redefine peer support services and deprive Medicare beneficiaries of the proven value of peer support.
I urge CMS to consider the following actions:
- Establish a dedicated set of services and a unique code for PSS, including only the services that align with peer support competencies and values
- Name this set of services to emphasize engagement, wellness, or recovery, rather than illness.
- If a specific code for PSS is not feasible, create a subset of PIN services that align with PSS competencies and remove PSS from the list of personnel providing the full range of PIN services.
Regarding training for PIN services:
- Ensure experienced PSS are responsible for developing content, determining training hours, and delivering training in alignment with peer support competencies, values, and ethics, following SAMHSA’s National Standards.
Regarding patient consent:
- Require patient consent for PIN services to uphold the principle of voluntary engagement.
Regarding PSS involvement in psychotherapy:
- Clarify that PSS do not provide psychotherapy and outline their distinct role in crisis services, in line with SAMHSA’s guidelines.
If these changes cannot be implemented:
- Exclude peer support specialists from the list of auxiliary personnel providing PIN services to maintain the integrity of evidence-based peer support services.
Thank you for your support in preserving the role, values, and ethics of the peer support profession.
(If you are a peer supporter, under “Comment Category” choose “Health Care Professional/Association – Other Healthcare Professional.”)