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Premier Comments on CY 2021 Proposed Outpatient and Physician Payment Rules

Premier submitted comments on the Center for Medicare & Medicaid Services (CMS) CY 2021 physician fee schedule (PFS) and outpatient prospective payment system (OPPS) proposed rules.

In its OPPS comment letter, Premier:

  • Urged caution as CMS looks to modify its Inpatient-Only (IPO) List and ambulatory surgical center Covered Procedures List and take proactive steps to mitigate the effects of these changes, particularly for alternative payment models, if finalized.
  • Opposed the proposed increased payment cuts to 340B drugs to ASP -28.7 percent.
  • Supported a more transparent and replicable methodology for Hospital Star Ratings and recommended improvements, including steps to account for more social risk factors and establishing star rating thresholds through annual rulemaking for the upcoming year.

In response to the PFS proposed rule, Premier:

  • Commented on proposed changes to the Medicare Shared Savings Program (MSSP), including voicing support for:1) reducing the number of measures but delaying significant changes to the MSSP quality standard until 2022 due to the PHE; 2) giving ACOs flexibility in reporting mechanisms; and 3) raising the quality performance threshold and allowing ACOs that meet the standard to receive full shared savings.
  • Supported continuing to include many of the services added during the public health emergency (PHE) on the telehealth list; expanding the list and continuing coverage and payment for audio-only telephone E/M services; and immediately allowing broad telehealth flexibilities for APMs.
  • Supported making workforce flexibilities granted during the public health emergency permanent.
  • For the Quality Payment Program:


    • Opposed adding the APM Performance Pathway (APP) as a new option for the Merit-based Incentive Payment System (MIPS) reporting and scoring and terminating the MIPS-APM scoring standard.
    • Urged CMS to commit to pay the Advanced APM incentive payment by 6/30 in future years.
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