27 Sep HCTTF Provides Input To CMS On CY 2020 QPP And PFS Proposed Updates

The Health Care Transformation Task Force appreciates the opportunity to comment on the Centers for Medicare and Medicaid Services (CMS) proposed revisions to payment policies under the Medicare Physician Fee Schedule, Quality Payment Program, and other revisions to Part B for CY 2020.

Task Force Response Summary

1. Medicare Shared Savings Program Requirements. HCTTF recommends that CMS provide sufficient time for MSSP ACOs to adjust to quality measure changes and when future changes are made.
2. Quality Payment Program. HCTTF urges CMS to commit to pay the Advanced APM incentive payment no later than June 30th in future years.
3. Merit-based Incentive Payment System. HCTTF encourages CMS to engage closely with stakeholders this year to design cost measures that are specifically aligned with clinical practice, to address existing challenges around MIPS data reporting, and to ensure the program promotes movement to APMs.
4. Advanced APMs. The HCTTF recommends that CMS expand the definition to include commercial medical home models that fit the standard to give providers in these arrangements credit for participation. HCTTF also encourages CMS to work with commercial payers to design a process that would allow for recognition of Other Payer Advanced APM programs with negotiable rates of marginal risk as long as individual provider arrangements meet minimum Advanced APM standards.
5.  Stark Advisory Opinion Process. HCTTF supports the proposals to make the Advisory Process more accessible, shorter in duration, and allow for greater reliance on final opinions. HCTTF urges CMS to implement an additional process beyond advisory opinions by offering official guidance on the scope and application of regulatory waivers for implemented APMs. HCTTF has long recommended that CMMI establish a core set of waivers that would be available for any CMMI APM participant, and then add additional waivers as need for particular models.

Read the letter