PEPC appreciates the opportunity to provide input on the proposed Calendar Year (CY) 2024 Medicare Physician Fee Schedule (PFS) rule. As outlined in the letter, our comments are framed with an eye toward ensuring that independent physicians and practices are well-positioned to move off the unsustainable fee-for-service (FFS) chassis and into value-based care models that reflect their unique practice and financial circumstances. As many value-based care models continue to be built on the FFS chassis, Medicare FFS payment rates and policies are integral to the success of CMS’ value-based care models. To that end, PEPC has deep concerns with CMS’ proposed decrease in the PFS conversion factor.
Additionally, PEPC appreciates several of CMS proposed changes to the Medicare Shared Savings Program (MSSP), which we believe will support independent physicians and practices in the transition to risk. We also respond to CMS’ request for information (RFI) on the future of MSSP, urging CMS to develop a full-risk optional track in MSSP that includes prospective population-based payments (capitation), and is designed with small and independent physicians in mind.
To read the full response, click here.