The AHA supports a number of proposed policy changes that ensure access to care, support public health efforts, improve quality and promote regulatory relief. Specifically, we strongly support CMS’s proposed reversal of its previously finalized policies for evaluation and management payments. The AHA also applauds CMS’s commitment to addressing the opioid crisis by proposing to implement the statutorily required payments for opioid treatment programs, and proposing a new bundled payment model for certain substance use disorders. We also appreciate that the agency again proposes mostly gradual, flexible increases to requirements under the Quality Payment Program for the CY 2020 performance period. We also welcome the agency’s willingness to review the current Advisory Opinion regulations for the physician self-referral law.
However, other proposed policies could prove highly problematic for the field. CMS’s proposed criteria for therapy assistant services are far too restrictive and administratively burdensome. The resulting payment cut would reduce resources for medically necessary services, including those needed to ensure patient safety. In addition, while we support the agency’s proposed OTP model, we are alarmed by the proposal to price the Part B injectable and implantable drugs used in the bundle using the average sales price without the legally mandated 6% add-on. Lastly, some of CMS’s proposed changes to the Merit-based Incentive Payment System – especially the increase in the number and weight of cost measures, and the proposed MIPS Value Pathways framework – require considerable revisions to ensure they assess providers fairly and accurately.