Associations Comment on Proposed MPFS Rule and Urge Immediate Changes


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

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

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

The breakdown of the MGMA’s main recommendations is as follows.

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

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

“The reductions resulting from the 4.42% drop in the CY 2023 conversion factor coupled with the potential impact of statutory pay-per-view are simply unsustainable,” the group said.

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

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

MGMA urges CMS to finalize proposal to bring telehealth services in line with the Consolidation Appropriations Act of 2022 and continue to allow certain telehealth services to remain on Medicare’s telehealth services list for 151 days after the expiration of the public health emergency, the MGMA said. The MGMA is also asking CMS to continue to cover and pay for audio-only tours at all times.

Adjust subgroup reporting requirements as part of the MIPS value pathway reporting option.

The MGMA says this will better reflect practices’ team-based care approaches and reduce unnecessary additional administrative hurdles.

“The MGMA has long advocated against requiring firms to form sub-groups for quality reporting activities. Practices leverage every member of the clinical team to support effective, patient-centered care. Quality reporting should support the team care approach and not compromise it,” the group says.

MGMA Senior Vice President of Government Affairs Anders Gilberg echoed those concerns in his statement.

“Staffing shortages compromise patient outcomes and increase practice costs and healthcare system waste. Looking ahead to Medicare’s payment policies in CY 2023, each proposed policy must be considered in the context of the state health system; one in which practices do not have too much time, staff, or resources to devote to administratively heavy tasks that do not add value or improve the quality of care provided to patients,” Gilberg said.

The AHA also released comments on the rule, many of which echoed those of the MGMA.

According to the AAHit is “deeply concerned” about CMS’s proposed changes to the Medicare Economic Index and urges the agency to suspend its update of the index.

“Furthermore, we continue to have concerns about the feasibility of MIPS value pathways, and believe that much work remains to be done to ensure that they result in fair and equitable performance comparisons between clinicians and MIPS groups,” the AHA said.

The AHA said that while it appreciates CMS’s proposals to improve access to behavioral health services, the association questions the usefulness and appropriateness of proposals related to family psychotherapy and chronic pain management.

Amanda Norris is Revenue Cycle Writer for HealthLeaders.


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