Commenting today on the Centers for Medicare & Medicaid Services’ physician fee schedule rule for calendar year 2022, the AHA expressed appreciation for the agency’s proposals that support care delivery and patient outcomes by extending the timeline for certain programs and continuing others beyond the end of the COVID-19 public health emergency. Specifically, the AHA said it supports CMS’ proposals to delay the payment penalty phase of the Appropriate Use Criteria program and the compliance date for e-prescribing of controlled substances, as well as proposals to extend temporary coverage of certain telehealth services and increase access to audio-only services for those who need them. The AHA also appreciated CMS’ proposal to delay until 2023 the implementation of the Merit-based Incentive Program’s Value Pathways approach, and the association continued to express concerns about the feasibility of the MIPS Value Pathways, saying “much work remains to be done to ensure they result in fair, equitable performance comparisons across MIPS clinicians and groups.” Concerned about the significant payments cuts in CMS’ proposals, the AHA highlighted concerns about the proposed cut to the conversion factor, as well as the agency’s proposed approach to updating clinical labor pricing rates. In addition, the AHA urged CMS to reevaluate its proposals to require routine, in-person visits for the coverage and payment of telehealth mental health services emphasizing that “access to these services would be greatly reduced for certain patients.”

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