Responding to the Centers for Medicare & Medicaid Services’ physician fee schedule proposed rule for calendar year 2021, the AHA said it appreciates the agency’s effort to continue certain pandemic-era policies that have helped hospitals and health systems ensure access to care for patients during the COVID-19 public health emergency.

“In particular, we support CMS’s proposal that would allow physicians and non-physician practitioners to continue providing direct supervision via interactive telecommunications technology; we urge the agency to make permanent this policy,” AHA said. “We also appreciate CMS’s proposals to permanently retain some of the telehealth services it added to the Medicare telehealth list of services during the PHE and temporarily retain other services it added during the PHE. The AHA also supports CMS’ proposal to delay until CY 2022 at the earliest implementation of the Merit-based Incentive Program’s Value Pathways approach.”

In addition, AHA also expressed concern about other proposed policies, particularly those made more problematic by the ongoing COVID-19 pandemic. “The proposed significant reduction to the Medicare conversion factor that is a result of CMS’ proposal to implement the evaluation & management (E/M) revaluation and other changes in a budget-neutral manner would significantly strain the finances of hospitals and health systems,” AHA said.  

Among other comments, AHA expressed concern regarding the proposal to create a new MIPS Advanced Payment Pathway that asks all MIPS alternative payment models to report the same six quality measures, as well as concerns about proposed changes to the Medicare Shared Savings Program quality measurement approach.

Read the full letter for AHA’s detailed comments on the rule.

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