On July 7, the Centers for Medicare & Medicaid Services (CMS) released the Calendar Year (CY) 2023 Medicare Physician Fee Schedule (MPFS) Proposed Rule. This proposed regulation includes several positive changes to the Medicare Shared Savings Program (MSSP) for which NAACOS has long advocated.
NAACOS is seeking member input on the proposals in this rule, which will help shape our comments. Please share your feedback by emailing us at advocacy@naacos.com. Comments to CMS in response to the proposed rule are due on September 6 and may be submitted on the regulations.gov website. NAACOS will provide draft comments ahead of the deadline.
CMS will review comments and issue a final rule later this year. Typically, the MPFS Final Rule is released by November 1.
Medicare Shared Savings Program Proposals
Change the “Pathways to Success” glidepath to allow more time before advancing to risk for certain ACOs*
Incorporate a prospectively projected administrative growth factor into a three-way blend with national and regional growth rates to update an ACO’s historical benchmark for each performance year*
Reduce the cap on negative regional adjustments from -5 percent to -1.5 percent*
Account for an ACO’s prior savings in rebased benchmarks to help mitigate the lowering of an ACO’s benchmark over time*
Revise how CMS applies the existing 3 percent cap on HCC risk score*
Change the quality scoring approach to allow more ACOs to achieve some savings*
Add a health equity adjustment increase for ACOs serving high proportions of underserved beneficiaries
Provide advance investment payments to certain ACOs*
Seek comment on the impact of the advanced APM incentives ending*
*Denotes policies for which NAACOS has long advocated
Medicare Physician Payment Proposals
Decrease the Medicare conversion factor from $33.59 to $33.08
Update other evaluation and management (E/M) visits to allow for time or medical decision making
Implement telehealth provisions established in the Consolidated Appropriations Act (CAA) of 2022
