PEPC Submits Comment Letter in Response to CY2025 Physician Fee Schedule

PEPC appreciates the opportunity to provide input on the proposed Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) rule. As outlined in the letter, our comments specifically focus how select provisions of the proposed rule will impact health care competition and value-based care opportunities for independent physicians.

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 the proposed decrease in the PFS conversion factor and urges CMS and Congress to work together to ensure a long-term solution to Medicare Part B reimbursement, including an inflation-based update to the conversion factor, to ensure physicians are adequately compensated for their services.

CMS also proposes a series of revisions to the Medicare Shared Savings Program (MSSP) intended to further advance Medicare’s value-based care strategy of growth, alignment, and equity. PEPC believes that these proposals, while well intentioned, will have minimal impact on encouraging independent physicians to enter a value-based care arrangement or take on more risk than they are today.

To read the full response, click here.

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