The Task Force Provides Input to CMS on CY 2022 MPFS Proposed Rule

The Health Care Transformation Task Force filed comments on the Centers for Medicare and Medicaid Services (CMS) Medicare Physician Fee Schedule (MPFS) Proposed Rule (CMS-1751-P).


  1. Telehealth Services: HCTTF supports efforts to expand access to telehealth (both video and audio-only) for behavioral health care services, and recommends that CMS remove provisions that require an in-person visit within six months of a telehealth behavioral health service visit. The Task Force also makes several other recommendations related to telehealth.
  2. Medicare Shared Savings Program (MSSP): The Task Force provides comments on a number of MSSP-related provisions, including amending the APM Performance Pathway Reporting Requirements for PY 2022 and 2023, promoting health equity and addressing health disparities within the MSSP, establishing transparency around the 30th (and 40th) percentile quality Performance Standards, and concerns related to TIN-level reporting for MSSP ACOs. The Task Force also provided extensive comments related to use of Regional FFS expenditures In Calculating ACOs’ Historical Benchmarks, including concerns related to the “Rural Glitch.”
  3. Medicare Diabetes Prevention Program:  The Task Force supports CMS proposed changes to the Medicare Diabetes Prevention Program (MDPP), and believe the changes will improve access to care without creating unintentional safety or financial consequences for patients or providers, in the context of the current public health emergency.
  4. Updates to the Quality Payment Program (QPP):  The Task Force reiterates its concerns – expressed in a previous comment letter in response to the Inpatient Prospective Payment System (IPPS) proposed rule – regarding the use of indirect estimation techniques to increase the volume of demographic data (specifically on race and ethnicity) available to identify disparities and address health equity gaps. The Task Force also supports CMS’ proposal to update the Complex Patient Bonus Formula, and poses clarifying questions to CMS regarding the design and implementation of the MIPS Value Pathways.

Read the Letter