AHA Regulatory Advisory
August 4, 2021
The Centers for Medicare & Medicaid Services (CMS) July 13 issued a proposed rule that would update physician fee schedule (PFS) payments for calendar year (CY) 2022. The rule also includes several proposals to implement changes to the quality payment program (QPP) created by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015.
We are pleased that the agency proposes to delay the payment penalty phase of the Appropriate Use Criteria (AUC) program, as well as expand access to telehealth for behavioral health services. However, we continue to have concerns regarding certain aspects of the pricing methodology for drugs administered as part of the Opioid Treatment Program benefit, including limitations on take-home supplies of naloxone. Moreover, we remain concerned about the feasibility of the Merit-Based Incentive Payment System (MIPS) Value Pathways, and believe much work remains to ensure they result in fair, equitable performance comparisons across MIPS clinicians and groups. Sign in to view the entire report.