CHPA and NAACOS comments to CMS on 2024 Medicare Physician Fee Schedule (MPFS) Rule

September 13, 2023 at 12:00 pm

On July 13, 2023, the Centers for Medicare & Medicaid Services (CMS) released the proposed 2024 Medicare Physician Fee Schedule (MPFS) Rule. The comment period ended on September 11th and both CHPA and the National Association of Accountable Care Organizations (NAACOs) submitted a comment letter. The comment letters addressed several positive changes for the Medicare Shared Savings Program (MSSP) that NAACOS has long been advocating for along with those that benefit FQHCs specifically. CHPA’s letter primarily addresses the Medicare Shared Savings Program (MSSP). In the letter, CHPA writes to support:

  • Changes to the quality performance standard and alignment of measures across its programs
  • Modifications to assignment methodologies and expanded window for assignment
  • Continued focus on benchmarking to include addressing the negative regional adjustment and the introduction of a new risk adjustment model
  • Allowing FQHCs to bill for remote patient monitoring
  • FQHCs expanded services regarding social determinants of health and the need for follow-up

Below are the comments submitted by CHPA and NAACOS: