Premier Provides CMS Feedback on Physician Payment and Value-Based Care Proposals for CY 2027

Premier submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the calendar year (CY) 2027 Medicare Physician Fee Schedule (PFS) and Medicare Shared Savings Program (MSSP) proposed rule. Key themes from Premier's comments include:

Medicare Shared Savings Program: Premier applauded CMS' proposed modifications to the MSSP, noting that many would address longstanding stakeholder concerns and strengthen incentives for accountable care participation. Among its recommendations, Premier urged CMS to:

• Finalize both the proposed regional adjustment and prior savings adjustment updates together to ensure fair and sustainable benchmarking;
• Preserve meaningful savings opportunities for accountable care organizations (ACOs) through the Accountable Care Prospective Trend (ACPT) methodology;
• Account for Medicare Advantage beneficiaries transitioning to traditional Medicare—who may be higher risk—in MSSP risk adjustment and financial methodologies;
• Extend Advance Incentive Payments to high-revenue ACOs; and
• Finalize proposed quality reporting improvements and strengthen safeguards around quality data submission and program accountability.

Ambulatory Specialty Care and MSSP Specialty Integration: Premier drew from its extensive experience working with health system ACOs that employ and partner with specialists to share lessons learned on specialty care integration in MSSP. Recommendations included:

• Improving primary care and specialty attribution methodologies to avoid distorting beneficiary accountability;
• Refining benchmarking for specialty-focused populations by using concurrent risk-adjustment approaches;
• Addressing interoperability challenges that pose the most significant operational barrier to specialist participation in value-based care;
• Providing additional waivers and regulatory flexibilities to support care coordination and data sharing; and
• Tailoring quality measurement processes to hold specialists accountable for meaningful measures.

Prospective Primary Care Payments in MSSP: Premier supported CMS' interest in advancing prospective primary care payments within MSSP and emphasized that successful capitation models should preserve the core principles of value-based care by:

• Reducing reliance on visit volume on both the front- and back-end, e.g., end-of-year true-ups of capitated payments based on utilization;
• Incorporating enhanced primary care payments within a broader risk-based payment model;
• Addressing MSSP’s assignment methodology to accurately count providers who provide primary care services; and
• Providing sufficient implementation time for participating organizations to make operational and compensation changes.

Transition to Digital Quality Measurement: Premier expressed support for CMS' goal of moving toward FHIR-based digital quality measurement, while urging a phased implementation strategy and greater support for providers. Among its recommendations, Premier called on CMS to:

• Adopt a three-year transition period for digital quality measures;
• Hold electronic health record vendors accountable for reporting readiness and interoperability capabilities;
• Give providers adequate time to validate data before performance accountability begins; and
• Provide longer timelines, technical assistance, incentives and financial support to help ACOs manage the costs and complexity of digital quality measure reporting.

Technology-Enabled Primary Care and Artificial Intelligence (AI): Premier encouraged CMS to focus on patient outcomes rather than technology adoption when designing future payment policies for AI-enabled care. Specifically, Premier recommended that CMS:

• Avoid creating AI-specific billing codes and instead link reimbursement to measurable outcomes;
• Establish governance expectations for organizations deploying AI-enabled technologies;
• Distinguish between reductions in administrative burden and reductions in physician work when considering payment valuation; and
• Continue monitoring evidence regarding AI's impact on provider capacity, quality and patient outcomes before making significant payment changes.

Alternative Payment Models (APMs): Premier raised concerns that CMS' proposal to apply qualifying Advanced APM participant determinations at the TIN/NPI level could unintentionally disadvantage clinicians who practice across multiple organizations or change employers after earning qualifying participant status. Premier urged CMS to maintain current policies to avoid weakening incentives for participation in advanced alternative payment models.