Today, the FAH submitted comments to CMS on the proposed rule for the Physician Fee Schedule (PFS) for the calendar year 2025. Comments focused on the following:

• Recommended that CMS work with Congress to avert physician payment cuts for 2025 and develop a longer-term approach that provides adequate physician payment. 
• Reiterated that there are multiple barriers to reporting on patient outcome measures for hip and knee surgery and urged CMS to propose solutions to these challenges that will move toward capturing and reporting data with minimal burden. 
• Urged CMS to delay or provide more flexibility for reporting electronic measures under the Merit-Based Incentive Payment System (MIPS).
• Urged CMS to ensure program stability and increase the meaningfulness of existing requirements for the physician quality payment program (QPP). 
• Highlighted FAH support for telehealth flexibilities in multiple contexts, such as for behavioral health services, direct supervision of services, teaching physicians, frequency limitations when providing telehealth services, and audio-only systems if a patient cannot or does not consent to video technology. 
• Supported streamlining certification of therapy plans of care and expanding coverage of colorectal cancer screening. 
• Supported CMS-proposed amendments for returning Medicare overpayments while urging CMS to ensure providers have adequate time to conduct a good-faith investigation of an overpayment.
• Supported CMS proposals to improve successful participation in the Medicare Shared Savings Program.

Read the comment letter here.