NYeC Submits Comments to CMS on the Proposed Medicare Physician Fee Schedule for CY 2021

On October 5, 2020, the New York eHealth Collaborative submitted comments to CMS on the Proposed calendar year (CY) 2021 Physician Fee Schedule, which includes updates to Medicare telehealth services, the Quality Payment Program, and other Medicare Part B initiatives. NYeC appreciates and applauds CMS for their continued commitment to improving quality, promoting interoperability, and demonstrating the value of health information exchange to improve health outcomes.

Some highlights from our comment include:

CMS proposed certain expansions for use of telehealth services under Medicare Part B given the COVID-19 public health emergency:

    • Recommend making the proposed change to the Medicare program’s definition of Direct Supervision permanent, thus allowing the supervising physician to be remote and use real-time, interactive audio-video technology
    • Advocate for the use of Health Information Exchanges (HIEs) to provide interoperability between telehealth data and data collected from in-person visits

CMS proposed updates to the Quality Payment Program (QPP), including updates to the Merit-based Incentive Payment System (MIPS) for Medicare Part B clinicians and the MIPS Value Pathways (MVP) framework:

    • Support the inclusion of the 5th MVP Guiding Principle stating that MVPs should support the transition to digital quality measures
    • Request that CMS continue to prioritize interoperability and health information exchange as a foundational requirement in the new MVP Program
    • Suggest that CMS strengthen quality measurement by further promoting HIE usage and learning from New York’s experience

CMS proposed updates to the MIPS Promoting Interoperability performance category, including the addition of a new, optional, Health Information Exchange (HIE) bi-directional measure:

    • Support extending the Prescription Drug Monitoring Program (PDMP) measure under the electronic prescribing objective as optional
    • Strongly support the alternative HIE measure under the health information exchange objective, with some clarifications
    • Recommend that CMS continue to include the alternative HIE measure as a required measure in the MVP program and request that CMS adopt a complementary measure in the Inpatient Promoting Interoperability Rules