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AV Responds to Annual Medicare Physician Fee Schedule Proposed Rule

A letter to the Centers for Medicare & Medicaid Services calls for reorienting health care around higher quality, less costly care.

Last week Arnold Ventures submitted a formal comment in response to the Centers for Medicare & Medicaid Services’ annual Medicare Physician Fee Schedule Proposed Rule. The proposed rule includes changes to the Fee Schedule, which determines how clinicians are paid for services provided to the 33 million Americans with traditional Medicare and influences how private insurers pay clinicians. Medicare’s Fee Schedule can play an important role in reorienting the entire health care system toward delivering higher quality, less costly care that meets patients’ individual needs.

Importantly, this year’s rule proposes changes to the Medicare Shared Savings Program, a promising payment alternative in which providers voluntarily come together under Accountable Care Organizations (ACOs) to offer coordinated and patient-centered care. Through ACOs, doctors and hospitals are rewarded for delivering high-quality care at lower costs. 

Arnold Ventures supports CMS’s proposed changes to increase participation in the Medicare Shared Savings Program. Specifically, we commend CMS for its efforts to improve the spending benchmarks used to determine ACOs’ savings and to assign more Medicare beneficiaries to ACOs. These changes can help increase participation and generate greater aggregate savings for Medicare. Arnold Ventures encourages CMS to contemplate additional strategies to achieve this dual aim. 

Arnold Ventures also recommends CMS implement a new payment model for primary care providers within the Medicare Shared Savings Program. The current fee-for-service payment structure rewards primary care providers for focusing on reimbursable services and visit volume, which runs contrary to the value-based incentives of an ACO to manage costs and improve population health. Implementing a hybrid capitated payment model for primary care providers would give clinicians flexibility to manage their own time and commit resources to important work that supports patients but is not strictly tied to a reimbursable service. This would better position providers to deliver comprehensive, personalized, and equitable care. 

Lastly, this year’s rule proposes adding a new fee-for-service billing code to compensate primary care providers more accurately for the time and resource costs associated with long-term patient relationships. Arnold Ventures supports this new code and calls on CMS to make additional changes, including initiating new data collection efforts, to more accurately determine payments for primary care and other services. 

Read the entire letter here.