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.