PAI Submits Comment Letter in Response to 2024 MPFS and QPP Proposed Rule

On September 11, PAI submitted a comment letter in response to CMS’ Calendar Year (CY) 2024 MPFS and QPP Proposed Rule. PAI strongly opposes the continued payment cuts for CY 2024 as a result of the proposed reduced conversion factor (CF). PAI underscored how the proposed rule fails to account for inflation in medical practice costs and COVID-exacerbated challenges to practice sustainability. The constant decrease to physician reimbursement creates long-term financial instability in the Medicare physician payment system and threatens patient access to Medicare-participating physicians. PAI highlighted how the Agency’s misguided approach to establishing physician payment rates under Medicare has also fueled the decade-long trend of consolidation by making it financially untenable for many physicians to sustain independent medical practices.

Overall, PAI urged CMS to work with Congress to prioritize payment reforms to prevent further erosion of physician-led practices that participate in Medicare, especially in urban and rural areas where access is already threatened if not endangered. PAI asked that CMS recognize the impact of the COVID-19 pandemic on physician practices and limit payment cuts and any major changes that would adversely impact patient access to care. CMS should ensure that all finalized policies account for these challenges, as well as the importance of supporting all physicians, including small and independent practices. In summary, PAI recommended that CMS take the following actions:

• Reverse proposed physician payment cuts. As a top priority, CMS must work with Congress to address the growing instability of the Medicare physician payment system by providing relief for the additional budget neutrality cut that is planned for 2024.
• Replace the separate conversion factors for qualifying alternative payment model (APM) participants and other physicians with a single conversion factor that provides for an update that is equal to the annual percentage increase in the Medicare Economic Index (MEI) beginning in 2024.
• Permanently finalize expanded telehealth flexibilities and ensure telehealth visits are reimbursed at parity with office visits.
• Provide more clarification on the complexity add-on code, particularly on when physicians can bill for the code and encourage the Agency to allow physicians to bill the add-on code with Other E/M visits, not just office/outpatient visits.
• Refrain from expanding the scope of practice of non-physician practitioners (NPPs) beyond that supported by their state licensure, education, and training.
• Reduce physician burden through less frequent changes in reporting requirements, further clarity for physicians, and the increased use of empirical data to support any changes to the Quality Payment Program (QPP).

Access PAI Comment Letter (PDF) here.