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PEPC appreciated the opportunity to provide input on the Federal Trade Commission’s (FTC) and Department of Justice’s (DOJ) draft update of the Merger Guidelines, which describe and guide the agencies’ review of mergers and acquisitions to determine compliance with federal antitrust laws. Our comments highlight the largely negative impact of provider consolidation on the health …

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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 …

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PEPC was pleased to respond to the Centers for Medicare and Medicaid Services’ (CMS) request for information (RFI) on an Episode-Based Payment Model. Our comments focus on specific considerations for the CMS Innovation Center to ensure that it develops future episode-based payment models that leverage past physician-led in similar models and reflects the unique clinical …

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On June 22, the House Energy and Commerce Subcommittee on Oversight and Investigations held a hearing on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), “MACRA Checkup: Assessing Implementation and Challenges that Remain for Patients and Doctors.”   PEPC submitted a statement for the record, urging Congress to consider how to leverage and encourage …

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PEPC was pleased to provide feedback on the HHS Office of the National Coordinator for Health Information Technology (ONC) proposed rule, “Health Data, Technology, and Interoperability: Certification Program Updates, Algorithm Transparency, and Information Sharing.” This rule would implement the Electronic Health Record (EHR) Reporting Program provision of the 21st Century Cures Act by establishing new …

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On April 26, the House Energy and Commerce Committee Health Subcommittee held a hearing on legislative solutions to lower health care costs through increased competition and transparency. PEPC submitted a statement for the record for the hearing, highlighting evidence of the detrimental impact of increasing provider consolidation and providing support and feedback on legislative proposals, …

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PEPC appreciated the opportunity to provide input on the Federal Trade Commission’s (FTC) proposed rule that would ban employers from imposing noncompete agreements on their workers. As outlined in the letter, we appreciate the FTC’s work to address anti-competitive business practices across our nation’s workforce, including in the health care industry, which is vital to …

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On March 28, the House Energy and Commerce Committee Health Subcommittee held a hearing focused on examining ideas to drive down the cost of health care through transparency and competition.  PEPC submitted a statement for the record for the hearing, highlighting concerns around increasing consolidation in the health care market and the urgency it creates …

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PEPC was pleased to respond to a Senate HELP Committee Request for Information (RFI) on the health care workforce, including drivers of the health care workforce shortage and potential solutions. Independent practices and physicians are facing major workforce challenges stemming from health care consolidation, inadequate reimbursement, and entrenched fee-for-service (FFS) policies, all of which are …

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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 …

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