The Medical Group Management Association, on Sept. 6 submitted comments to CMS Administrator Chiquita Brooks-LaSure in response to the 2023 physician fee schedule proposed rule.
Three key recommendations from the MGMA, which represents more than 15,000 medical groups comprising more than 350,000 physicians:
1. The MGMA urged Congress to provide a positive update to the Medicare conversion factor in 2023 and all future years. The association said it is concerned with the estimated reduction to the conversion factor and how it would affect medical groups that are already challenged with rising costs, inflation, staffing woes and the continued effects of the COVID-19 pandemic.
"The cuts stemming from the 4.42 percent decrease in the 2023 conversion factor paired with the potential impact of the Statutory Pay-As-You Go Act are simply unsustainable," Anders Gilberg, MGMA's senior vice president of government affairs, wrote in the letter to CMS. "In an MGMA poll conducted on Aug. 30, 90 percent of medical practices report that the projected reduction to 2023 Medicare payment will reduce access to care."
2. The association asked CMS to finalize the proposal to align telehealth services with the 2022 Consolidations Appropriations Act and continue to permit certain telehealth services to remain on the Medicare telehealth services list for 151 days after the expiration of the public health emergency in addition to continuing to cover and pay for audio-only visits permanently.
3. The MGMA also asked CMS to adjust subgroup reporting requirements under the merit-based incentive payment system value pathways option to better reflect practices' team-based approaches to care and alleviate unnecessary administrative hurdles.
The association advocates 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, according to Mr. Gilberg.