Physician Fee Schedule Advances Accountable Care Policy. The Centers for Medicare & Medicaid Services (CMS) released the annual Medicare Physician Fee Schedule proposed rule, including a 2.8% reduction to the conversion factor. The proposed rule also contains several notable provisions related to the Medicare Shared Savings Program (MSSP), including proposing the establishment of a new prepaid shared savings option for certain ACOs and a health equity benchmark adjustment. The agency did not propose a new “full risk” track that many stakeholders had urged CMS to put forward in last year’s physician fee schedule, instead it includes a more detailed request for information relating to that track. The proposed rule also specifies how the agency proposes to mitigate the impact of significant, anomalous and highly suspect billing activity by excluding certain payment amounts from ACO financial calculations. The proposed rule would create a new advanced primary care management services bundle. And, the proposed rule includes a request for information soliciting feedback on the design of a potential mandatory ambulatory specialty care model to increase the engagement of specialists in value-based care. The rule is expected to be published in the Federal Register the week of July 15. A4H members will have a call on July 19 to discuss the proposed rule and the new proposals on this topic contained in the Physician Fee Schedule.

Health Information Technology Proposed Rule. The HHS Office of the National Coordinator for Health Information Technology (ONC) released the Health Data, Technology, and Interoperability: Patient Engagement, Information Sharing, and Public Health Interoperability (HTI-2) proposed rule. The proposed rule includes proposals for: standards adoption; certification criteria to advance public health data exchange; expanded uses of certified application programming interfaces, such as for electronic prior authorization and patient access; and information sharing under the information blocking regulations and the Trusted Exchange Framework and Common Agreement (TEFCA). Comments are due 60 days after publication of the rule in Federal Register with publication expected the week of July 15.

Proposed Rule to Address Anomalous Billing in MSSP. CMS issued a proposed rule that would adjust the MSSP financial methodology to account for significant, anomalous, and highly suspect (SAHS) billing activity related to two billing codes for urinary catheters. The comment period on the proposed rule closes July 29. In addition, the CMS Innovation Center shared guidance with ACO REACH participants on this issue. A4H members will have a call on proposals related to SAHS billing on July 19. A4H members can contact Shelley Robinette (srobinette@accountableforhealth.org) to be added to the call.

Health Affairs Article Highlights Value-Based Payment. The publication, titled “The Road To Value Can’t Be Paved With A Broken Medicare Physician Fee Schedule,” calls for reforms to the fee-for-service (FFS) payment system while noting that the Medicare Physician Fee Schedule is an intrinsic part of alternative payment models. The article stresses that FFS and value-based payment should be leveraged to complement one another. The authors demonstrate that the fee schedule can accommodate bundled payments and population-based payments, and they call on CMS to value services adequately and establish a hybrid primary care payment. Hybrid payments continue to be of interest to lawmakers and the Administration.

Success of Medicaid APMs. A recent study published in the Journal of the American Medical Association (JAMA) Internal Medicine found that Medicaid programs with APM options at federally qualified health centers (FQHCs) experience increases in care quality, particularly at FQHCs that place an explicit emphasis on quality. The study also found that more eligible patients received common health screenings after their state implemented APMs.

Double Click on Accountable Care. Save the date for upcoming in-person meetings in Washington, DC for policy-focused audiences. Details to follow.

Tuesday, September 10, 2024 – Register here
Thursday, December 12, 2024 – Register here