Commenting on the proposed Medicare physician fee schedule rule for calendar year (CY) 2016, Premier responded to the Centers for Medicare & Medicaid Services (CMS)’ proposals on payment and quality policies, as well as changes to the Medicare Shared Savings Program (MSSP). Read our full comment letter here.
In response to proposals on the MSSP, Premier did not support the statin measure proposed by CMS and urged it to focus on the development of electronic clinical quality measures (eCQMs). Premier did voice support for CMS’ proposal to refine the beneficiary assignment policy that is based on utilization of primary care services to more accurately reflect what constitutes such services.
In regards to proposed changes to the value-based payment modifier (VM), Premier strongly supported exempting eligible professionals who participate in Pioneer ACOs, the CPC initiative and other Innovation Center models from application of the VM, but further suggested that this proposal be extended to EPs who participate in the MSSP. Premier also urged CMS to incorporate the multi-payer nature and enhanced payments for care management services that are made through the Comprehensive Primary Care Initiative into other Medicare models, such as bundled payments and ACOs, to support aligned provider incentives and better outcomes for patients.
Premier made preliminary recommendations on the development of the Merit-based Incentive Payment System (MIPS) and the alternative payment model (APM) option, which were enacted as part of the Medicare Access and CHIP Reauthorization Act (MACRA) to replace the current physician reporting and quality programs starting in 2019. These comments focused on the low volume threshold in MIPS, the definition of eligible alternative payment models (APM) and what should qualify as nominal financial risk for an APM.
Among other comments, Premier expressed general support for CMS’ proposals on primary care and care management services, advance care planning, Medicare telehealth services and the physician self-referral law.