06 Oct HCTTF Provides Input To CMS On CY 2021 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 2021.
Task Force Response Summary
- Telehealth and Other Services Involving Communications Technology. HCTTF agrees there is value in allowing physicians to furnish additional telehealth services via Medicare, and for patients to receive broader access to care through telehealth. HCTTF encourages CMS to update telehealth policies for Alternative Payment Models (APMs). Specifically, HCTTF recommends that CMS include the following telehealth related waivers for current and future MIPS and Advanced APM participants: originating site restrictions, asynchronous service delivery, telehealth cost-sharing, cross-state licensure, establishing patient relationships, remote patient monitoring, and direct supervision flexibilities.
- Medicare Shared Savings Program Requirements. HCTTF urges CMS to introduce a transition year and finalize any changes to the reporting mechanism no earlier than CY 2022 to allow providers adequate time to adapt, particularly given they continue to grapple with the impact of the COVID-19 pandemic on their operations. The same leniency afforded to MIPS-eligible clinicians should be afforded to ACOs. HCTTF is concerned that the reduced APM Performance Pathway (APP) measure set has removed all preventive health measures, shifting the focus to the management of illness and cost rather than prevention. HCTTF does not support the implementation of the proposed quality performance standard in 2021 as providers still manage and recover from the pandemic and are without pre-established benchmarks to measure against and opposes the proposal to eliminate the pay-for-reporting year. HCTTF supports the proposed change to modify the EUC to consider the higher of an ACO’s 2020 quality performance score or its 2019 quality performance score used for financial reconciliation.
- Merit-based Incentive Payment System. HCTTF encourages CMS to maintain the APM Scoring Standard. While the APP eliminates the burden for MSSP ACOs, the elimination of the APM scoring standard shifts that burden to non-ACO MIPS APM participants.
- Advanced APMs. HCTTF urges CMS to pay the Advanced APM incentive payment no later than June 3oth in future years and encourages CMS to implement an appeal process related to these payments. The Task Force encourages CMS to make a conforming accommodation for Advanced APMs that use prospective alignments and exclude beneficiaries who were not eligible for assignment during that entity’s prospective assignment lookback period. HCTTF believes CMS should convene a Technical Expert Panel to advise on alternative methods for defining “attribution-eligible beneficiaries” for purposes of calculating the QP Threshold for groups and individuals with specialists outside of primary care.