The Task Force Provides Input to CMS on the Medicare Physician Fee Schedule Proposed Rule

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-1784-P). The Task Force’s letter focused on proposals across three main areas: Community Health Integration, the Medicare Shared Savings Program, and the Quality Payment Program.  

  1. COMMUNITY HEALTH INTEGRATION: CMS proposed new codes covering Community Health Integration (CHI) services that can be billed by care teams, including Community Health Workers, to address a range of health-related social needs for patients. HCTTF and our members recognize the value of team-based care and applaud CMS for acting to directly pay for the value Community Health Workers, care navigators, and others bring to these teams. As proposed, CMS plans to require an Evaluation and Management visit to qualify Medicare beneficiaries for these services. The Task Force urges CMS to allow hospital and emergency department visits to also act as initiating events for these services in recognition of the fact that beneficiaries most in need of CHI often lack a usual source of primary care. The Task Force also offered feedback to CMS on requirements for CHW certification requirements and the allowable frequency and duration of billing for CHI services.   
  2. MEDICARE SHARED SAVINGS PROGRAM (MSSP): CMS proposed several changes intended to refine the MSSP program and address concerns raised by ACOs and other stakeholders. Major proposals include:  
    • Changes to the MSSP quality reporting requirements (including allowing for Medicare only Clinical Quality Measure reporting and aligning ACO Performance Improvement (PI) reporting requirements to MIPS). The Task Force supports the proposal to allow ACOs the option to report Medicare CQMs for only their assignable Medicare population but oppose aligning ACOs to MIPS for PI reporting due to the increased reporting burden this would place on ACOs).
    • Medicare beneficiary assignment methodology changes (e.g., creating an expanded 24-month window for patient assignment to ACOs). HCTTF supports the intent of this proposal and agrees with the need to capture data more accurately on assignable ACO beneficiaries. The Task Force notes the potential for a longer assignment window to result in ACO assignment of Medicare beneficiaries without an active primary relationship with providers in the ACO.
    • Updates to the benchmarking methodology (e.g., eliminating the negative regional adjustment for ACOs and capping the regional service area risk score growth). The Task Force was broadly supportive of the proposed benchmarking changes.  
  3. UPDATES TO THE QUALITY PAYMENT PROGRAM (QPP): CMS proposed to end entity level QP determinations and to make all QP determinations at the individual level beginning with the QP Performance Period for CY 2024. CMS noted concerns about entity level QP determination creating disincentives for ACOs to include specialists and for providers with little to no involvement in APMs to benefit from the entity level QP determination. While HCTTF appreciates the concerns raised by CMS, we oppose this proposed strategy due to the additional administrative burden this would place on ACOs. Instead, to encourage greater specialist engagement, HCTTF encourages CMS to allow TIN NPI selection in MSSP to allow ACOs to target specific specialists for participation as opposed to an entire practice.  

Read the Letter Here