The Academy submitted comments in response to a congressional Request for Information (RFI) seeking suggestions on how to stabilize the Medicare physician payment system, including reforming the current payment structure so it supports a system that provides greater value to patients and to clinicians. The Academy provided specific recommendations on the Medicare Physician Payment System as well as Medicare’s Quality Payment Program.
On the topic of the Medicare Physician Payment System, the Academy urges Congress to:
- Stop the scheduled 4.42 percent budget neutrality cut to 2023 Medicare physician fee schedule payments,
- End the statutory annual freeze,
- Require an update to the Medicare Economic Index update for 2023, and
- Waive the four percent PAYGO sequester triggered by passage of the American Rescue Plan Act.
On the topic of Medicare’s Quality Payment Program, the Academy reaffirms its support of the participation of audiologists in quality measurement reporting.
“We believe it is important to demonstrate quality care as the health-care marketplace continues to underscore the importance of value. We support the inclusion of a designated specialty measures set for audiology and appreciate the options for participation in the Merit-Based Incentive Payment System (MIPS) that take into consideration the unique care provided by audiologists to Medicare beneficiaries. It will be imperative that Congress allow audiologists to continue to participate in quality reporting through the traditional MIPS program pathway for the next several years, to allow time to better understand how audiology might be included under the MIPS Value Pathway (MVP) program.
Audiology is currently exempt from both the cost and promoting interoperability categories. These exemptions need to be maintained. Many audiologists have not fully adopted electronic health record (EHR) systems due to several factors, including cost, the applicability of such platforms to audiology practices (many platforms are physician-focused), and the fact that audiologists were never considered as eligible professionals in the Medicare EHR Incentive Program.”
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