AHA Comments on CMS’s Physician Fee Schedule Proposed Rule for Calendar Year 2024

The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G Washington, DC 20201

Submitted Electronically

RE: CMS–1784–P Medicare and Medicaid Programs; CY 2024 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Advantage; Medicare and Medicaid Provider and Supplier Enrollment Policies; and Basic Health Program

Dear Administrator Brooks-LaSure:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations; our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers; and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) physician fee schedule (PFS) proposed rule for calendar year (CY) 2024.

We are deeply concerned with CMS’ proposed payment update, which would reduce payments approximately 3.3% from their CY 2023 levels. This negative update would pose significant risks to patients’ access to care and health systems’ financial stability, particularly for providers serving historically marginalized communities. Our concern is heightened by the fact that this cut is coming in the wake of over three years of unrelenting financial pressures on the health care system due to COVID-19, along with rising inflation, increasing input costs, and persisting staffing shortages and supply chain disruptions.

At the same time, the AHA applauds CMS’ proposals to extend through 2024 many of the COVID-19 telehealth flexibilities. In addition, the AHA continues to encourage CMS to work with Congress on permanent adoption of waiver provisions such as eliminating the originating and geographic site restrictions for all telehealth services and expanding telehealth eligibility to certain practitioners. We also encourage CMS to leverage its existing statutory authority to make permanent other waivers as appropriate.

We are also pleased that CMS is proposing to delay implementation of its split/shared visit policy and revised Medicare Economic Index (MEI), both of which would have resulted in significant reductions and redistributions in physician revenue on top of this proposed rule’s other cuts. In addition, we are encouraged by the agency’s proposed reevaluation of the Appropriate Use Criteria for Advanced Diagnostic Imaging program. We have expressed longstanding concerns that the current program could result in inappropriate claims denials, increased administrative burden and ultimately unnecessary delays in patient care.

We appreciate your consideration of these issues. Our detailed comments are attached. Please contact me if you have questions or feel free to have a member of your team contact Jennifer Holloman, AHA’s senior associate director of policy, regarding the payment provisions, at jholloman@aha.org, or Akin Demehin, AHA’s senior director of policy, pertaining to the quality provisions, at ademehin@aha.org.



Stacey Hughes
Executive Vice President