The Task Force Provides Input to CMS on CY 2023 MPFS 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-1770-P). The Proposed Rule outlined several important policy changes of interest to HCTTF members. The Task Force letter focused on proposals across three main areas: telehealth, the Medicare Shared Savings Program, and the Quality Payment Program.  


  1. TELEHEALTH SERVICES: HCTTF recognizes the growing role of telehealth services in the wake of the pandemic and supports the use of telehealth services for providing effective and efficient person-centered, value-based care. In the letter, we recommended that CMS reconsider their proposals to end coverage and payment for audio-only evaluation and management services and require an in-person mental health visit every six months to maintain access to telehealth services. Our position is that these policy changes are overly restrictive and, rather than protecting beneficiaries or improving quality, could result in some beneficiaries losing access to services. In addition to these points, the Task Force makes several other recommendations related to telehealth. 
  1. MEDICARE SHARED SAVINGS PROGRAM (MSSP): CMS proposed several changes intended to improve access to the MSSP program for inexperienced ACOs and address long standing issues with aspects of the program methodology such as benchmarking and risk adjustment. HCTTF is broadly supportive of CMS recognizing the need for upfront financial support for inexperienced ACOs, smoother glidepaths for ACOs transitioning to performance-based risk, and benchmarking and risk adjustment methodologies intended to sustain long-term participation in the program. Many of these changes are consistent in spirit with recommendations for improving MSSP that HCTTF submitted to CMS in the fall of 2021. In our comment letter we offer CMS detailed feedback on several MSSP proposals including the creation of the Advanced Incentive Payment program, allowing inexperienced ACOs to participate in upside only risk for up to 7 years, adjusting ACO benchmarks for prior savings, and a request for information on the design of an administrative benchmarking methodology to replace the current MSSP benchmarking approach. Find additional comments and recommendations in the letter.  
  1. UPDATES TO THE QUALITY PAYMENT PROGRAM (QPP):  The Task Force supports adding a social drivers of health screening measure into MIPS, requesting APM entities to report the Promoting Interoperability performance category at the APM Entity level, and permanently establishing the eight percent nominal risk standard when determining APMs that qualify as an AAPM. The Task Force also responds to requests for information on MIPS quality performance category, the proposed transition to individual QP determination, the transition from APM incentive payments to the enhanced PFS conversion factor update for QPs, and the MIPS quality performance and equity.  

Read the Letter