On September 9, 2024, the Alliance of Specialty Medicine submitted detailed comments to the Centers for Medicare and Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure on policy proposals included in the CY 2025 Medicare Physician Fee Schedule (MPFS) proposed rule. The Alliance, representing over 100,000 specialty physicians from 16 societies, highlighted several key concerns and made multiple recommendations to improve specialty care access through Medicare payment and policy.
Payment Proposals
In response to CMS’ proposed 2.8% reduction in Medicare payments to physicians, the Alliance called on CMS to collaborate with Congress on a permanent fix to ensure that physician payment rates reflect practice costs, emphasizing the impact of inflation over the last several years. The Alliance also endorsed CMS’s decision to delay updating cost data sources until the completion of the AMA’s Physician Practice Information Survey (PPIS) while supporting a regular and consistent update process for direct and indirect practice expenses.
Quality Improvement
The Alliance expressed concern about transitioning from the traditional Merit-Based Incentive Payment System (MIPS) to MIPS Value Pathways (MVPs), highlighting gaps in applicable measures for many specialties. Specialists urged CMS to retain flexibility for clinicians and avoid mandating subgroup reporting, which could place an undue burden on multi-specialty practices without providing meaningful improvements in quality measurement. The Alliance also supported CMS’s proposal to revise the cost performance category scoring methodology, which would reward clinicians with median performance more fairly. It also recommended that CMS retroactively apply these improvements to previous performance years or, at a minimum, zero out the weight of the cost category for prior years. The entire letter can be accessed by clicking the link below.
