Providers pushed back on CMS' plans to overhaul the Quality Payment Program with a new push toward value-based arrangements. They said it is not ready to implement and eventually replace the Merit-based Incentive Payment System.
In comments on the 2022 Physician Fee Schedule, hospital and medical practice groups also decried the 3.89% reduction to the conversion factor, partly because of budget neutrality requirements. The American Hospital Association said it was "concerned that the conversion factor cut will have an extremely negative affect on patients' access to certain services. Our concern is heightened by the fact that this cut is coming amidst nearly two years of unrelenting financial pressure on the health care system due to the ongoing COVID-19 PHE."
AHA suggested CMS work with Congress to maintain a 3.75% increase that is scheduled only for this year, put in place by the Consolidated Appropriations Act, or seek a waiver to pay-go requirements.
One key aspect of the proposed rule was increasing telehealth access by extending coverage of certain services and removing some geographic restrictions for mental health diagnosis and treatment.
While providers strongly support the telehealth coverage increases proposed in the PFS, they asked the agency to go further by putting the services that are now going to be covered through the end of 2023 on the permanent list.
Also, while approving of the inclusion of coverage for audio-only mental health visits, they opposed the requirement that the patient have an in-person visit within six months of the audio visit.
The Federation of American Hospitals, which represents for-profit hospitals, said it is concerned about overly burdensome documentation requirements for audio-only visits, such as mandating documentation in the patients' charts that the service is clinically appropriate. "If CMS takes the alternative path of imposing a rigid rule-based approach, it likely would stifle innovation in care delivery and undermine telehealth's potential to expand access to services in a specialty plagued by severe provider shortages," the group wrote.
The proposed PFS calls for beginning use of the value pathways program in MIPS for 2023 and having it replace MIPS entirely in 2027. MVP is intended to align clinician reporting requirements, but AHA said it's unclear whether the program would reduce administrative burden as expected or that it would be equitable across specialties. AHA said it "believes that unless and until CMS can address several conceptual issues with MVPs ... CMS should not set a date certain for transitioning to mandatory MVP participation."
The Medical Group Management Association and FAH also had concerns, particularly about provider burden.
Group purchasing organization Premier addressed the proposed rule's changes to reporting from accountable care organizations. It applauded the more gradual move to using electronic clinical quality measures, citing the reporting burden associated with them. Premier also asked CMS to recognize that ACO reporting is "fundamentally different from reporting by clinicians and groups."
The National Association of ACOs echoed those comments.
In responding to a request for information included in the rule on improving health equity, Premier advised against using algorithms to indirectly estimate race and ethnicity and recommended that "all efforts to stratify measures by race and ethnicity begin with confidential reporting and appropriate risk adjustment to account for factors associated with outcomes that cannot be addressed by providers."
AHA also opposed indirect estimation, saying it has the potential to lead to measurement bias.