What You Need to Know About the 2023 Medicare Physician Fee Schedule Proposed Rule

What You Need to Know About the 2023 Medicare Physician Fee Schedule Proposed Rule

What happened?

On July 7, 2022, the Centers for Medicare & Medicaid Services (CMS) issued the Calendar Year (CY) 2023 Calendar Year (CY) 2023 Physician Fee Schedule (PFS) Proposed Rule which includes proposed changes to the Medicare Shared Savings Program (MSSP).

Why is it important?

CMS is proposing changes to the MSSP. If finalized, the proposed rule would:

  • Change quality reporting and quality performance requirements
  • Alter the current “Pathways to Success” glidepath to provide more time before advancing to risk
  • Extend the incentive for reporting eCQMs/MIPS CQMs through performance year (PY) 2024
  • Implement a health equity adjustment to ACO’s quality performance category score
  • Institute benchmarking policies to establish quality measure benchmarks and minimum attainment level for CMS Web Interface measures
  • Expand the eligibility criteria to qualify for shared savings beginning January 1, 2024
  • Improve the risk adjustment methodology
  • Reduce administrative burden for ACOs while maintaining program integrity

It is CMS’ hope that these changes will advance its value-based care strategy of growth, alignment, and equity. Specifically, if finalized, these proposed changes will:

  • Further align policies under MSSP and the Center for Medicare & Medicaid Innovation’s ACO models.
  • Reduce administrative burden for ACOs
  • Provide opportunities and flexibility for rural providers and ACOs inexperienced with performance-based risk
  • Address the impact of increasing ACO market penetration on benchmarks
  • Ensure high performing ACOs have incentives to remain in the program long-term
  • Better account for medically complex, high-cost beneficiaries and guard against coding initiatives

How does this impact you?

  • Starting July 22, 2022, eligible ACOs that want to indicate interest in the proposed policy to remain in their current Level A or Level B participation of the BASIC track’s glide path must do so via ACO-MS.
  • CMS is requesting comment on the proposed changes. There will be a 60-day public comment period that closes September 6, 2022. Comments can be submitted at: https://www.regulations.gov/ (in commenting please refer to file code CMS-1770-P).

CHESS applauds CMS on their proposed changes and believes these are strategic and needed to see their goal of every Medicare beneficiary in an accountable care relationship by 2030 achieved. CHESS is reviewing the final rule and will submit comments to CMS on these proposed changes related to the Medicare Shared Savings Program.

About the Author

Melissa Pollock Headshot

Melissa Pollock, M.Div., CHC

Director, ACO Compliance and Regulatory Affairs at CHESS