The Medical Group Management Association commented on CMS' calendar year 2025 physician fee schedule and quality payment program proposed rule.
MGMA said it believes that CMS should consider ] the following items, according to a letter presented on Sept. 9:
1. MGMA is concerned with the estimated reduction to the calendar year 2025 conversion factor and its impact on medical group practices, and wants to work with Congress to provide a positive update to the Medicare conversion factor in calendar year 2025 and all future years.
2. As medical groups continue to take advantage of telehealth, MGMA wants to work with Congress to extend telehealth flexibilities past the end of 2024 while utilizing its full statutory authority to permanently cover telehealth services.
3. MGMA urges CMS to finalize many of the telehealth proposals, including permanently covering audio-only visits, extending its direct supervision policy and distant site practitioner provisions, while continuing to promote the appropriate use of telehealth.
4. MGMA encourages the finalization of the Medicare overpayments proposal that would allow for the suspension of the 60-day repayment deadline under certain circumstances including when a provider identifies an overpayment but needs more time to investigate its full extent.
5. MGMA is urging CMS to provide further clarity and guidance surrounding the utilization of HCPCS code G2211 while moving forward with allowing G2211 to be billed with annual wellness visits, vaccine administration and any Medicare Part B preventative services.
6. MGMA wants to work with CMS to reduce the significant administrative burden medical groups face under the current construction of the Merit-based Incentive Payment System. CMS is urged to examine comprehensive changes to MIPS through its regulatory authority and working with Congress.
7. CMS should ensure its methodology avoids unsustainable increases to a MIPS performance threshold that is already too high, and finalizes maintaining the MIPS performance threshold at 75 points.
8. MGMA urges CMS to not sunset the MIPS program before MVPs and other value-based care models are mature enough to capture the full spectrum of medical groups.
9. MGMA urges CMS to reverse promoting interoperability performance category reporting requirements set to take effect in 2025 within the Medicare Shared Savings Program.
10. MGMA appreciates CMS including proposals meant to promote participation in accountable care organizations. The agency should ensure these policies are not in conflict with other proposals that may dissuade participation.
11. MGMA urges CMS to work with Congress to reinstate the Advanced Payment Model incentive payment at 5% and maintain the current Qualifying APM Participant thresholds instead of increasing them.