Premier submitted comments on the Centers for Medicare & Medicaid Services (CMS)’ CY 2022 Medicare physician fee schedule (PFS) proposed rule, providing input on proposed changes to physician payments and quality programs, as well as to the Medicare Shared Savings Program (MSSP).
In regard to CMS’ proposed changes to the MSSP, Premier recommends that CMS continue to collect more data and stakeholder feedback prior to requiring accountable care organizations (ACOs) to adopt these new reporting requirements and quality standard. Additionally, Premier recommends several changes to improve the ACO quality reporting standard, including:
- Recognizing the reporting burden with electronic clinical quality measures (eCQMs);
- Recognizing ACO reporting as fundamentally different from reporting by clinicians and groups;
- Retaining the current quality performance standard;
- Reducing the data completeness threshold and explore sampling approaches;
- Seeking additional input on MSSP quality measure set; and
- Retaining pay-for-reporting option for new entities or when measures are newly introduced or modified.
Premier also recommends that CMS increase the MSSP risk score cap to 5 percent and apply symmetrical cap on decreases in risk score.
Finally, Premier supports delaying the payment penalty phase for its Appropriate Use Criteria (AUC) program for advanced diagnostic imaging and request that CMS continue to work with provider and vendors to rapidly resolve any remaining implementation issues.