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Association Comments on CY 2023 Physician Fee Schedule Proposed Rule

In response to the calendar year (CY) 2023 Physician Fee Schedule proposed rule, America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to adequately reimburse off-campus, provider-based departments (PBDs) and refine physician quality reporting to account for costs of care and the unique needs of patients essential hospitals serve.

The association urged the agency in a Sept. 6 letter to:

  • preserve adequate reimbursement rates for essential hospitals’ PBDs;
  • broaden the scope and Medicare reimbursement of telehealth services;
  • adopt policies in the Medicare Shared Savings Program (MSSP) that promote more robust participation by essential hospitals, including upfront payments and longer time in one-sided-only tracks;
  • continue to refine the Quality Payment Program by ensuring that measures, including new equity measures in the Merit-based Incentive Payment System (MIPS), are tested for validity; and
  • continue the complex patient bonus in the MIPS and examine alternative approaches to target the bonus to clinicians with higher caseloads of complex patients.

The association also responded to requests for information on adequate reimbursement of community health workers, new survey questions in the Consumer Assessment of Healthcare Providers and Systems for MIPS, and incorporation of social determinants of health measures in the MSSP.

Additionally, America’s Essential Hospitals recommended that CMS codify a definition of essential hospitals that the agency can use to enact Medicare policies to protect and support hospitals that disproportionately serve marginalized people   

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


About the Author

Maryellen Guinan is a principal policy analyst at America's Essential Hospitals.

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