Last week HHS released their final rules on the Medicare Annual Wellness Visit for the establishment of a Personalized Prevention Plan. You can access the PDF here
, the key section begins on page 737.
HHS received many comments on their draft rules that discussed the HRA and many other issues:
One special concern of a number of commenters was related to the health risk assessment (HRA). Some provisions of section 4103 of the ACA require the HRA be included in the new AWV, which is effective January 1, 2011. Other provisions of section 4103 of the ACA give the Secretary a longer period of time to develop an HRA in consultation with relevant groups and entities.
And further on
We agree with commenters that the HRA is an important part of the AWV and we are working to fully implement this relevant provision of the ACA. However, because the statute has specified a time frame and procedures that require consultation with relevant groups and entities prior to publication of the required HRA guidelines it is not possible to complete those procedures by January 1, 2011. Moreover, we do not believe it would be prudent to mandate an interim HRA without completing the consultation process that Congress has specifically required.
HHS’s final decision appears to be in part based on statements by the AMA and other physician groups that there needs to be standardization and input before putting the HRA into action. While I can understand the AMA’s position, HRA’s have been used successfully for years by physicians working with corporations and those in Preventive Medicine and studies have validated their results.
As HHS moves forward with this process to develop a standard HRA, they stated that the CDC is planning to convene an open scientific meeting in early 2011 to facilitate the development of an HRA. HHS also said that
CMS has also commissioned a technology assessment from the Agency for Healthcare Research and Quality (AHRQ) to be completed by the end of 2010 that will help in the development of the HRA guidelines and model.
A decision by HHS to allow for the interim use of “qualified” HRA’s would have ensured that these visits truly met the intentions of Congress to provide a comprehensive new type of visit and would also have given providers unique insights into their patients. I hope that consensus is reached and a viable HRA developed quickly; for ultimately the lack of one being included with the this visit will be felt by the Medicare beneficiaries who will not receive the full value of a true “Wellness Visit to Establish a Personalized Prevention Plan.”