PEPC appreciates the opportunity to provide input on the proposed Calendar Year (CY) 2022 Medicare Physician Fee Schedule (PFS) rule. As outlined in the letter, we appreciate the steps taken by the Centers for Medicare & Medicaid Services (CMS) to reduce physician burden in impactful ways, and encourage CMS to consider additional steps it may take to further encourage physicians to move away from fee-for-service delivery models.
PEPC is supportive of the proposed MIPS Value Pathways (MVPs) and encourages CMS to leverage MVPs as an optional, voluntary platform to facilitate the transition of more physicians and physician-led practices to value-based care. While PEPC supports CMS’ proposal to delay implementation of the eCQM requirements to allow Accountable Care Organizations (ACOs) additional time, we urge CMS to consider whether the framework for aligning Medicare Shared Savings Program (MSSP) and Merit-based Incentive Payment System (MIPS) program quality measures continue to incentivize and reward high-quality care. Finally, we strongly urge CMS to immediately adopt policies to address the MSSP “rural glitch,” thus fixing a technical issue that disincentivizes adoption of ACOs by providers in rural areas. As a result of this methodology flaw, Medicare beneficiaries in rural areas have less access to providers participating in delivery system models that incentivize cost-effective, high-quality care compared to their urban counterparts.
Read more here in the letter.