September 6, 2022 at 8:00 am
On July 7, 2022, the Centers for Medicare & Medicaid Services (CMS) released the proposed 2023 Medicare Physician Fee Schedule (MPFS) Rule. The comment period ended on September 6th and CHPA submitted a comment letter primarily addressing MSSP. The comment letter addressed several positive changes for the Medicare Shared Savings Program that NAACOS has long been advocating for along with those that benefit FQHCs specifically. These included the continued allowance of telehealth services on par with fee for service providers, inclusion of social determinants of health factors in risk scoring, and improvements and recognition of the relative impact the dual-eligible population has on FQHC performance compared to other MSSP providers. Additionally, comments were included regarding the proposed benefits to incent the less experienced ACOs and afford these opportunities to organizations like CHPA that have more experience yet still face similar challenges related to innovation, infrastructure and risk exposure. Along with these, support was given to modification of the benchmarking methodology to adjust for the ratcheting effect, reduction of the cap on negative regional adjustments and recognition of the impact on ACO prior savings on the benchmark measures.
Below are the comments submitted by CHPA and the National Association of Accountable Care Organizations (NAACOs):
- CHPA comments
- NAACOS comments