Associations Comment on MPFS Proposed Rule, Urge Immediate Changes

Medical groups are urging Congress to provide a positive update to the Medicare conversion factor as well as other changes for 2023.

The Medical Group Management Association (MGMA) and the American Hospital Association (AHA) both submitted comprehensive comments to CMS in response to the 2023 Medicare Physician Fee Schedule (MPFS) proposed rule.

The MGMA is urging Congress to provide a positive update to the conversion factor, finalize the proposal to align telehealth services, and adjust subgroup reporting requirements under the MIPS value pathways, among other changes for 2023.

The breakdown of the MGMA's key recommendations are as follows.

Urge Congress to provide a positive update to the Medicare conversion factor in 2023 and all future years.

MGMA is deeply concerned with the estimated reduction to the 2023 conversion factor and its potential impact on medical group practices, MGMA said in its statement.

"The cuts stemming from the 4.42% decrease in the CY 2023 conversion factor paired with the potential impact of Statutory Pay-As-You Go are simply unsustainable," the group said.

According to the MGMA, in poll conducted last month, 90% of medical practices report that the projected reduction to 2023 Medicare payment will reduce access to care.

Finalize the proposal to align telehealth services with the Consolidations Appropriations Act.

The MGMA is urging CMS to finalize the proposal to align telehealth services with the 2022 Consolidations Appropriations Act and continue to allow certain telehealth services to remain on the Medicare telehealth services list for 151 days after the expiration of the public health emergency, the MGMA said. The MGMA is also requesting CMS continue to cover and pay for audio-only visits permanently.

Adjust subgroup reporting requirements under the MIPS value pathways reporting option.

The MGMA says doing so will better reflect practices' team-based approaches to care and alleviate unnecessary additional administrative hurdles.

"MGMA has long advocated against requiring practices to form subgroups for quality reporting activities. Practices leverage every member of the clinical team to support effective and patient-centered care. Quality reporting should support the team-based approach to care and not undermine it," the group said.

The MGMA’s SVP of Government Affairs Anders Gilberg echoed these concerns in his statement.

"Staffing shortages jeopardize patient outcomes and increase costs for practices and waste for the healthcare system. Looking ahead to Medicare payment policies in CY 2023, each proposed policy must be considered in the context of the current state of the healthcare system; one in which practices do not have excess time, staff, or resources to devote to administratively burdensome tasks that neither add value nor improve the quality of care provided to patients," Gilberg said.

The AHA also released comments on the rule, many of which resounded the MGMA's.

According to the AHA, it has "strong concerns" about CMS' proposed changes to the Medicare economic index and urges the agency to pause its update of the index.

"In addition, we continue to have concerns about the feasibility of the MIPS value pathways, and believe much work remains to be done to ensure they result in fair, equitable performance comparisons across MIPS clinicians and groups," the AHA said.

The AHA said while it appreciates CMS' proposals to improve access to behavioral health services, the association questions the utility and adequacy of the proposals related to family psychotherapy and chronic pain management.