PEPC appreciates the opportunity to provide input on the proposed Calendar Year (CY) 2024 Advance Notice of Methodological Changes for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (Advance Notice). As outlined in the letter, we appreciate the steps taken by the Centers for Medicare & Medicaid Services (CMS) to ensure Medicare beneficiaries receive more equitable, high quality, and whole-person care that is affordable and sustainable.
Our comments focus on how the proposed policies in the MA Advance Notice will impact independent physicians and practices participating in, or considering participating in, value-based care models in MA as well as Medicare fee-for-service (FFS):
- Value-Based Care in Medicare Advantage: PEPC continues to support for efforts to encourage further value-based payment adoption in MA, including through incorporating a value-based care Star measure and harmonizing existing measures to reduce burden on small and independent practices.
- Impact of Proposed MA HCC Model Changes on Value-Based Care: PEPC urges CMS to consider the far-reaching impact of model changes in their analysis when considering finalizing any changes, including applying CMS-Hierarchical Condition Categories (HCC) model updates to value-based care models.
- Ensuring Adequate Physician Payment: It is critical to ensure that physician payment is not impacted by proposals in the Advance Notice, as many independent practices continue to operate on very low margins and at a competitive disadvantage compared to other practice settings that receive higher payments for the same services.
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