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Commenting yesterday on the physician fee schedule proposed rule for calendar year 2023, AHA said it appreciates the proposals to support care delivery and patient outcomes, particularly those to improve Medicare Shared Savings Program stability and flexibility. AHA said it also supports the Centers for Medicare & Medicaid Services’ proposal to delay implementing its revised “split” or “shared” evaluation and management visit policy; prioritize using health-equity-related measures in the Merit-based Incentive Payment System; and implement a health equity adjustment for the MSSP. 

“However, we have strong concerns about CMS’s proposed changes to the Medicare Economic Index and urge the agency to pause its update of the index,” AHA wrote. “In addition, we continue to have concerns about the feasibility of the 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. Finally, while we appreciate CMS’ proposals to improve access to behavioral health services, we question the utility and adequacy of the proposals related to family psychotherapy and chronic pain management.”