September 4, 2024 – Premier has submitted feedback on the proposed rulemaking for the Doctor Price Schedule (PFS) for calendar yr (CY) 2025. In our detailed feedback, Premier urged CMS to:
- Eliminating the arbitrary distinction between excessive and low incomes in MSSP;
- Enhance insurance policies associated to the Medicare Shared Financial savings Program (MSSP) to make sure Accountable Care Organizations (ACOs) will be profitable throughout the program, together with by:
- Reaching a extra acceptable transition to the brand new Medicare Shared Financial savings Program (MSSP) high quality reporting necessities, together with guaranteeing that the necessities are in step with CMS's digital high quality measurement technique, that no further measures are added to the MSSP high quality measures, and that the necessities are piloted earlier than being broadly applied;
- Modifying the proposed shared financial savings possibility to permit ACOs to make use of funds for extra actions and scale back reporting necessities;
- Modifying the proposed Well being Fairness Adjustment to make sure that extra ACOs and underserved communities can profit from the coverage;
- Finalizing proposals to determine a course of to deal with the affect of great, anomalous, and extremely suspicious billing actions on MSSP ACOs and persevering with to work with ACOs to enhance the method for reporting suspected fraud, waste, and abuse;
- Creating a better danger possibility inside MSSP, whereas sustaining the prevailing ENHANCED trajectory;
- Finalizing modifications to the necessities for reporting follow-on beneficiaries and contemplating further modifications to the reporting course of and different flexibilities to allow ACOs to higher talk with beneficiaries in a significant means;
- Withdrawal of the brand new necessities for licensed EHR expertise (CEHRT) for ACOs;
- Finalize the proposal to permit using audio-only expertise for telehealth companies underneath sure circumstances; and
- Finalize the proposal to align the implementation date for the Digital Narcotics Prescribing Program (EPCS) for long-term care prescribers with the timeline for updating the NCPDP SCRIPT requirements.
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