Premier Comments on Proposed Rule to Hold Medicare ACOs Harmless from Anomalous DME Billing

Premier submitted comments in response to the Centers for Medicare & Medicaid Services (CMS)’ proposed rule aimed at mitigating the negative impacts of anomalous durable medical equipment (DME) billing on ACOs participating in the Medicare Shared Savings Program (MSSP). In its letter, Premier applauds CMS for taking swift action to address the concerns we have raised around abnormal catheter billing and the negative impact it has had on MSSP ACO financial performance. Premier strongly supports CMS’ proposal to remove all Medicare Parts A and B payments for catheter HCPCS codes (A4352 and A4353) from expenditure and revenue calculations for CY 2023. As covered in our response, this action will help to ensure that ACOs are held harmless for spending that is outside of their control.