FAH Hospital Policy Blog

Perspectives on health policy affecting America's hospitals and the patients we serve.

FAH Policy Blog Team

FAH Submits Comments on CY 23 Physician Fee Schedule Proposed Rule 

Today, FAH submitted comments to CMS regarding the physician fee schedule proposed rule for calendar year 2023.  The comments focused on a number of issues, including FAH support for extending multiple Medicare telehealth services for 151 days beyond the end of the COVID-19 public health emergency PHE), including a delay of the in-person visit requirement for mental health services furnished via telehealth.  (CMS already has extended many other Medicare telehealth services through December 31, 2023.)  Other comments focused on: 

  • Making permanent current PHE flexibilities for direct supervision requirements through use of real-time audio-visual technology. 
  • Payment valuation, methodology, and new codes for certain services, such as cardiac ablation, evaluation and management services, wound care management products/skin substitutes, and remote therapeutic monitoring. 
  • Expansion of services to address the increasing demand for behavioral health services 
  • Use of modifiers for single-dose container or package drugs. 

The letter also focused on extensive proposals for the Medicare Shard Savings Program (MSSP) and updates to the Quality Payment Program.  Key comments focused on: 

  • Commending CMS for undertaking a holistic and futuristic view of the MSSP and proposing changes to increase both the number of ACOs and number of people served by ACOs. 
  • Scaling shared savings and shared losses for PY 2023 as a way of recognizing genuine efforts by ACOs to meet quality and cost targets even when they fall somewhat short of the previously established all-or-nothing savings/loss thresholds. 
  • Highlighting the imbalance in CY 2024 proposals that support ACOs based on ACO revenue and Medicare performance-based risk-bearing experience. 
  • Health equity and the inclusion of a health equity adjustment for ACOs’ proposed quality measure calculation and application of bonus payments.  

You can read the entire comment letter here