APMA submitted comments in response to CMS’ Medicare and Medicaid Programs: CY 2024 Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment, etc., on September 11. APMA’s extensive comments focused on the following concerns, among others:
Medicare Physician Fee Schedule (MPFS) Conversion Factor
APMA is urging CMS to pursue opportunities to mitigate the impact of the proposed conversion factor reductions for 2024, including working with Congress to enact a legislative remedy. We further urge CMS to engage with Congress and stakeholders to develop and enact real reform to the Physician Fee Schedule (PFS) that ensures physicians can consistently rely on sustainable payments over the long term.
Evaluation and Management (E/M) Visits
CMS is planning to activate HCPCS G2211. APMA opposes CMS’ proposal to change the status indicator for G2211 to “active” and begin payment for this service for several reasons:
Telephone E/M Services
APMA appreciates ongoing payment for telephone E/M services through 2024 and asks that this policy be made permanent.
Appropriate Use Criteria for Advanced Diagnostic Imaging
APMA applauds and supports CMS’ proposal to pause efforts to implement the Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging Services program for reevaluation and to rescind the current AUC program regulations.
Payment for Skin Substitutes
APMA urges CMS to move away from its attachment to changing the methodology for paying for skin substitutes furnished in physician offices and treating them as “incident to supplies.” Instead, APMA believes CMS should continue its long-standing policy of recognizing and providing separate payment for these products under the ASP methodology described in section 1847A of the Social Security Act (SSA). ASP pricing would ensure that there is differentiated payment for differentiated products. Different products deliver different benefits to patients, and they vary in composition, cost, and size.
MIPS Performance Threshold for Experienced and New Participating Clinicians
CMS proposes to raise the MIPS performance threshold from 75 to 82 points. APMA believes that most clinicians who have not fully participated in MIPS since 2019 will find this goal to be unsurmountable. Under the rules set forth by Congress, CMS is only required to set the threshold at the mean or median of the final scores of all MIPS eligible clinicians from a “prior period” identified by CMS, meaning CMS has the authority already to maintain the performance threshold at 75 points for 2024. Given the reality of numerous recent exemptions and reduced participation in the program, APMA strongly urges CMS to maintain the performance threshold at 75 points and to work with Congress to find solutions that will give CMS more flexibility to determine the most appropriate performance threshold(s) for future years.
APMA also submitted comments on the CY 2024 Proposed Rule on Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; etc. APMA, as a member of the Alliance of Wound Care Stakeholders, supported the comments of the alliance and asked CMS to implement the recommendations provided to and approved by the Advisory Panel on Hospital Outpatient Payment. These recommendations, if implemented by CMS, will help correct the flaws that exist in the payment methodology as well as inappropriate APC assignments for cellular and or tissue-based products for skin wounds (CTPs) which have impacted access to care in hospital outpatient departments (HOPDs). The recommendations included:
Read both comment letters in their entirety at www.apma.org/comments. Read the APMA Weekly Focus for additional updates and contact the APMA Health Policy and Practice Department with any additional concerns or comments.