PEPC appreciates the opportunity to provide input on the proposed Calendar Year (CY) 2023 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 and support independent practices and providers entering value-based care models, 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 CMS’ proposals to incorporate an option into MSSP to make advance investment payments (AIPs) to certain ACOs, as access to capital can be a barrier in taking on financial risk and participating in value-based models for many independent providers and practices. We also support proposed policies aimed at smoothing the transition to risk, which allow independent practices and physicians to choose a path to value-based care that is right for them, but urge CMS to ensure its policies strike a balance with the urgency required by CMS’ ambitious goals of getting all Medicare patients into accountable care relationships by 2030. PEPC also provides feedback on specific benchmarking proposals. We encourage CMS to fully address the “rural glitch” and remove an ACO’s own beneficiaries from benchmark calculations. We also urge CMS not to finalize the proposed Accountable Care Prospective Trend (ACPT) policy, which would create stark winners and losers based on geography, but to instead work with stakeholders to assess benchmarking changes that will achieve CMS’ goals and may be more equitably applied.
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