The NPPC also wishes to express support for the MTM benefit in Medicare. As longtime advocates for this intervention, we strongly support the Food Is Medicine Coalition (FIMC)’s technical comment on the MTM questions stated in the comment. We believe that CMS should create separate coding and payment for MTMs as an incident-to service. Such a change would both reflect current evidence of impact and address a critical gap in access to medically tailored nutrition in the Medicare program. We agree with the points raised in FIMC’s submission and believe their comment accurately reflects the views of the NPPC. We respectfully urge the agency to give full consideration to the recommendations outlined in FIMC’s comment.
However, we also encourage CMS to consider PRx to be a prescribable benefit under clinician-determined medical necessity. In this comment we provide an explanation for why and how a PRx benefit should be considered under the same incident-to framework.”