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Association Comments on CY 2022 Physician Fee Schedule Proposed Rule

In a letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commented on the calendar year (CY) 2022 Physician Fee Schedule (PFS) proposed rule.

The rule includes provisions important to essential hospitals, related to Medicare reimbursement for telehealth services, vaccine payment rates, the Quality Payment Program (QPP), and the Medicare Shared Savings Program (MSSP).

The rule also included a request for information (RFI) to address health equity through improved data collection to better measure and analyze disparities across its programs.

In comments to CMS, the association urged the agency to:

  • ensure essential hospitals are adequately reimbursed for complex services provided in their provider-based departments to further promote access to care in the nation’s most marginalized communities;
  • expand disadvantaged populations’ access to lifesaving services by broadening the scope of telehealth reimbursement and lifting barriers to Medicare reimbursement for these services;
  • finalize its proposal to delay the penalty phase of its new appropriate use criteria for advanced diagnostic imaging;
  • reimburse providers for complex medication management services when performed by clinical pharmacists incident to a physician or nonphysician practitioner;
  • continue to refine the QPP by delaying mandatory reporting under the new MIPS Value Pathways (MVPs) to allow adequate time to test MVPs and ensure there will be MVP options for all participants;
  • delay sunsetting traditional MIPS until a transition plan for participants is clearly outlined;
  • increase the complex patient bonus in the MIPS and examine alternative approaches to target the bonus to clinicians with higher caseloads of complex patients;
  • provide additional time before removing the CMS Web Interface as a reporting option for accountable care organizations (ACOs) and further assist ACOs in transitioning to the new APP; and
  • consider changes to the MSSP to improve participation by ACOs serving complex patients who are impacted by social risk factors that influence outcomes.

Additionally, in response to the RFI on health equity in the rule, the association recommended that CMS:

  • promote culturally appropriate collection of patient race, ethnicity, and language data and information on social risk factors in a standardized and useful way to help identify disparities and target improvement activities to achieve equity;
  • continue to refine its disparity methods reports to include social risk factors beyond dual eligibility and race and ethnicity; and
  • refrain from publicly reporting results that use indirect estimation for race and ethnicity. 

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with additional questions.


About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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