Premier submitted comments on the calendar year (CY) 2025 Physician Fee Schedule (PFS) proposed rule. In our detailed comments, Premier urged CMS to:
- Eliminating the arbitrary high-low revenue distinction in MSSP;
- Establishing a more adequate transition to the new Medicare Shared Savings Program (MSSP) quality reporting requirements, including ensuring requirements are consistent with CMS’ digital quality measurement strategy, not adding more measures to the MSSP quality measure set and piloting requirements prior to broad adoption;
- Modifying the proposed prepaid shared savings option to allow ACOs to utilize funds for additional activities and reduce reporting requirements;
- Modifying the proposed health equity adjustment to ensure more ACOs and underserved communities may benefit from the policy;