AHA Detailed Comments on CMS' Proposed PFS Rule

September 13, 2021
The Honorable Chiquita Brooks-LaSure
Administrator
Centers for Medicare & Medicaid Services
7500 Security Blvd
Baltimore, MD 21244

RE: CMS-1751-P, Medicare Program; CY 2022 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Provider Enrollment Regulation Updates; Provider and Supplier Prepayment and Post-payment Medical Review Requirements

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations; our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers; and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) physician fee schedule (PFS) proposed rule for calendar year (CY) 2022. We appreciate CMS’ proposals in this rule that support care delivery and patient outcomes by extending the timeline for certain programs and continuing others beyond the end of the COVID-19 public health emergency. In particular, we support CMS’ proposal to delay the payment penalty phase of the Appropriate Use Criteria (AUC) program and the compliance date for e-prescribing of controlled substances. We also appreciate CMS’ proposals to extend temporary coverage of certain telehealth services and increase access to audio-only services for those who need them. Finally, the AHA also supports CMS’ proposal to delay until 2023 the implementation of the Merit-based Incentive Program’s Value Pathways (MVP) approach.

However, we continue to have concerns about the feasibility of the Merit-Based Incentive Payment System (MIPS) Value Pathways, and believe much work remains to be done to ensure they result in fair, equitable performance comparisons across MIPS clinicians and groups. In addition, we urge CMS to reevaluate its proposals to require routine, in-person visits for the coverage and payment of telehealth mental health services. If these policies are finalized as proposed, access to these services would be greatly reduced for certain patients.

We appreciate your consideration of these issues. Our detailed comments are attached. Please contact me if you have questions or feel free to have a member of your team contact Shira Hollander, AHA’s senior associate director of policy, at shollander@aha.org, regarding the payment provisions, or Akin Demehin, AHA’s director of policy, at ademehin@aha.org, pertaining to the quality provisions.

Sincerely,

/s/

Stacey Hughes
Executive Vice President
Enclosure

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