Premier Responds to CY 2025 Physician Fee Schedule Proposed Rule

Premier submitted comments on the calendar year (CY) 2025 Physician Fee Schedule (PFS) proposed rule. In our detailed comments, Premier urged CMS to:

• Improve policies related to the Medicare Shared Savings Program (MSSP) to ensure accountable care organizations (ACOs) can succeed under the program, including by:
  • Establishing a more adequate transition to the new Medicare Shared Savings Program (MSSP) quality reporting requirements, including ensuring requirements are consistent with CMS’ digital quality measurement strategy, not adding more measures to the MSSP quality measure set and piloting requirements prior to broad adoption;
  • Modifying the proposed prepaid shared savings option to allow ACOs to utilize funds for additional activities and reduce reporting requirements;
  • Modifying the proposed health equity adjustment to ensure more ACOs and underserved communities may benefit from the policy;
  • Finalizing proposals to establish process for addressing the impact of significant, anomalous, and highly suspect billing activities on MSSP ACOs and continue to work with ACOs to improve the process for reporting suspected fraud, waste and abuse;
  • Establishing a higher risk option within MSSP while maintaining the existing ENHANCED Track;
  • Finalizing changes to follow-up beneficiary notification requirements and consider additional changes to the notification process and other flexibilities to allow ACOs to better engage with beneficiaries in meaningful ways;
  • Repealing the new certified EHR technology (CEHRT) requirements for ACOs;
  • Eliminating the arbitrary high-low revenue distinction in MSSP;
• Finalize its proposal to allow use of audio-only technology for telehealth services under certain circumstances; and
• Finalize its proposal to align the implementation date for Electronic Prescribing of Controlled Substances (EPCS) Program for long-term care prescribers with the timeline for updating the NCPDP SCRIPT standards.