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Premier Submits Comments on the Proposed CY 2023 Medicare Physician Fee Schedule

Premier submitted comments on the calendar year (CY) 2023 Medicare Physician Fee Schedule (PFS) proposed rule.

As part of this rule, the Centers for Medicare & Medicaid Services (CMS) proposes several notable policy changes to the Medicare Shared Savings Program (MSSP) aimed at attracting new ACO participants, sustaining participation of existing ACOs, and advancing health equity. In its comments, Premier applauds CMS for taking action to not only support growth in the program but also to address several well-known issues that have made it challenging for ACOs to continue participation. As discussed in more detail in its letter, Premier:

  • Supports CMS’ proposals to smooth the transition to two-sided risk by giving ACOs additional time in one-sided risk tracks and allowing all ACOs to remain at BASIC Level E;
  • Strongly urges CMS to eliminate the high-low revenue distinction across all MSSP policies, as supported by Premier’s new analysis;
  • Recommends key revisions to CMS proposal for Advanced Investment Payment, including expanding eligibility to ensure safety net providers are included and to maximize efforts to advance health equity;
  • Strongly urges CMS to establish a more adequate transition to new electronic clinical quality measures (eCQMs) / Merit-based Incentive Payment System (MIPS) CQM reporting requirements, including ensuring requirements are consistent with CMS’ digital quality measurement strategy and piloting requirements prior to broad adoption;
  • Recommends CMS revise eligibility for its proposed health equity adjustment and reconsider its design to incentivize social determinants of heath (SDOH) data collection;
  • Supports CMS’ broader goals of adopting an administratively-set benchmark, but strongly urge CMS to work with stakeholders to refine methodologies before broader adoption, including evaluating impacts of the pandemic on healthcare utilization and trends; and
  • Supports proposed changes to risk adjustment methodology but continues to urge CMS to increase the risk score caps to 5 percent and apply a symmetrical cap on decrease in risk scores.
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