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AAMC Comments on 2022 Medicare Physician Fee Schedule Proposed Rule

September 17, 2021

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CONTACTS
Gayle Lee, Director, Physician Payment & Quality
Phoebe Ramsey, Sr. Regulatory Analyst, Quality & Payment Policy
Ki Stewart, Policy and Regulatory Analyst

The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) on Sept. 13 in response to the 2022 Medicare Physician Fee Schedule proposed rule. In its comments, the AAMC urged the CMS to prevent steep cuts to physician payments by supporting stakeholders’ efforts to persuade Congress to maintain the 3.75% increase to the conversion factor for at least the next two years and prevent payment cuts in 2022 due to sequestration. If Congress does not act on budget neutrality before Jan. 1, 2022, the AAMC strongly urged the Department of Health and Human Services to use the public health emergency declaration as a basis to ensure access to care and mitigate financial impacts due to the COVID-19 pandemic by waiving budget neutrality adjustments.

The AAMC opposed some of the payment policies proposed in the rule regarding split (shared) visits and critical care services, recommending that the CMS seek further input from stakeholders on the delivery of critical care services before finalizing these proposed changes. The AAMC supported proposals to expand telehealth (including audio-only technology) services for mental health and encouraged the CMS to make permanent other COVID-19 telehealth waivers to further expand telehealth. The AAMC also supported the proposal to delay enforcement of the Appropriate Use Criteria (AUC) Program by at least one year or until the end of the COVID-19 public health emergency, and the association strongly recommended that the CMS exclude advanced diagnostic imaging services that are performed as part of a clinical trial from the AUC program. The AAMC also responded to proposals for the Medicare Shared Savings Program, including support for maintaining the option to report quality measures through the group practice reporting option web interface for at least the next two performance years as the program transitions to electronic clinical quality measurement.

On the Quality Payment Program, the AAMC supported the proposal to delay the transition to the Merit-based Incentive Payment System (MIPS) Value Pathway (MVP) to address implementation concerns. The AAMC urged the CMS to make MVP reporting voluntary, allowing clinicians to determine which reporting option is most meaningful and least burdensome. It generally supported the concept of subgroup reporting and recommended that practices identify which clinicians would be part of the subgroup. The AAMC cautioned the CMS against ending traditional MIPS at the end of 2027. Additionally, the AAMC recommended that the CMS maintain the cost measure performance category weight at 20%, given concerns with attribution, risk adjustment, and the impacts of the COVID-19 public health emergency. The AAMC also responded to the CMS’ requests for information (RFIs) in support of their efforts to take a thoughtful, evidence-based approach to incorporating additional data collection to address health inequities.

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