10 Sep The Task Force Provides Input to CMS on the Medicare Physician Fee Schedule Proposed Rule
Posted at 11:24h
in Policy Communications
The Health Care Transformation Task Force submitted comments on the Centers for Medicare and Medicaid Services (CMS) Medicare Physician Fee Schedule (MPFS) Proposed Rule (CMS-1807-P). The Task Force’s letter focused on proposals across four main areas: Medicare Shared Savings Program (MSSP); Center for Medicare and Medicaid Innovation (CMMI) model elements; specialty care; and primary care and health equity.
- MSSP: CMS proposed several changes intended to refine the MSSP program and address concerns raised by accountable care organizations (ACOs) and other stakeholders. Major proposals include:
- Prepaid shared savings for MSSP Accountable Care Organizations that have previously earned shared savings. The Task Force supports the option for prepaid shared savings but recommends that CMS remove the prohibition against using prepaid shared savings to pay performance incentives.
- Health Equity Benchmark Adjustment for agreement periods starting 1/1/25 and later. The Task Force strongly supports this proposal and recommends CMS expand the beneficiaries included in the adjustment calculation.
- Alternative Payment Model (APM) Performance Pathways Plus (APP) quality measure set to be required for MSSP ACOs starting in 2025. MSSP ACOs would be required to report several new measures as electronic Clinical Quality Measures (eCQMs) or as Medicare CQMs. The Task Force recommends CMS delay all newly proposed APP Plus quality measures until at least 2027, to give ACOs and other APM entities time to prepare to report additional eCQMs.
- Removal of significant, anomalous, and highly suspect (SAHS) billing activity. The Task Force supports this proposal to recalculate performance year and benchmark expenditures for CY2024 and later.
- Beneficiary notification policies. The Task Force supports the proposed modifications to this policy and recommends additional changes to reduce beneficiary confusion and operational complexity.
- Request for Information (RFI) on a higher risk track within MSSP. The Task Force recommended that CMS adopt a new ENHANCED Plus risk track to supplement the current ENHANCED track.
- CMMI Model Elements: CMS proposed several policies that build upon CMMI model elements. Major proposals include:
- New payments for cardiovascular risk assessment and management services. The Task Force is supportive of the new codes as a means of increasing preventive care, improving quality, and supporting population health.
- Three new Advanced Primary Care Management codes, including: Principle Care Management, Transitional Care Management, and Chronic Care Management. The Task Force is supportive of CMS’ goal of providing support to primary care practices by offering stability for their care management infrastructure. However, the Task Force believes the APCM proposals should be refined to increase their adoption.
- RFI on hybrid primary care payments. The Task Force supports primary care capitation as an option for Advanced APM participants.
- Specialty Care:
- Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs). Task Force is supportive of the underlying concept behind MVPs but offers several recommendations to strengthen the program.
- RFI on specialist engagement in value-based care. The Task Force supports specialist engagement in VBC but recommends exempting Advanced APM participants from any future mandatory model.
- Primary Care & Health Equity:
- Policies that support patients and caregivers through high-quality primary care, integrated behavioral health, and related services. The Task Force supports these new codes because they collectively support integrated, whole-person care.
- RFI on patient-reported outcome measures and community health integration. The Task Force supports the policy objectives for both RFIs and provided additional information to support successful implementation.