What the 2022 Physician Fee Schedule Pitch Means for Health Equity

The Centers for Medicare & Medicaid Services has unveiled its 2022 Physician Fee Schedule proposal, and among the changes it is making to certain reimbursement programs, the agency is bringing health equity to the forefront.

Particularly, CMS is soliciting comment from providers in certain alternative payment models (APMs) about how they can better collect information about health disparities.

“Over the past year, the public health emergency has highlighted the disparities in the U.S. health care system, while at the same time demonstrating the positive impact of innovative policies to reduce these disparities,” CMS Administrator Chiquita Brooks-LaSure said in a public statement.

“CMS aims to take the lessons learned during this time and move forward toward a system where no patient is left out and everyone has access to comprehensive quality health services.”

These efforts will foremost entail soliciting comment from certain APM participants about how they can collect and report health equity data among the Medicare population. Currently, ACOs are only responsible for quality reporting on a limited set of Medicare patients; CMS maintains that reporting on all Medicare patients will help ensure clinical quality improvement across all Medicare beneficiaries, better delivering on health equity.

“However, we are seeking comments and recommendations on how ACOs can utilize their resources to ensure that patients, regardless of racial/ethnic group, geographic location and/or income status, have access to equal care and how ACOs can improve the quality of care provided to certain communities, while addressing the disparities that currently exist in healthcare,” CMS wrote in the proposed rule, which was published in the Federal Register.

Additionally, CMS is seeking public comment on how it and other federal agencies can compel value-based care participation from organizations treating more vulnerable populations. CMS said it was open to adjusting certain reporting benchmarks for organizations treating particularly vulnerable or high-risk populations.

What’s more, CMS is looking into how it can improve health equity for Medicare populations in a way that protects patient privacy. These efforts could take the form of confidential health equity reports related to gender or sexual identity, race and ethnicity, dual eligibility, disability, and rurality.

CMS said such reports could help overall efforts to close the health equity gap. On a micro scale, hospitals and smaller clinician practices could use the information to shape health equity efforts aimed at closing care disparities.

In addition to headway on health equity, the PFS proposal also includes patient care access and other patient-facing issues. For example, CMS seeks to extend some of the COVID-era telehealth flexibilities in an effort to expand patient access to care. Particularly, CMS is looking to telehealth in the behavioral healthcare space.

“The COVID-19 pandemic has put enormous strain on families and individuals, making access to behavioral health services more crucial than ever,” Brooks-LaSure said. “The changes we are proposing will enhance the availability of telehealth and similar options for behavioral health care to those in need, especially in traditionally underserved communities.”

Finally, the PFS seeks to improve participation in the diabetes prevention program, a key chronic disease prevention initiative out of CMS. The agency proposed waiving the participation fee for organizations that apply by January 1, 2022, as well as some reimbursement adjustments that CMS said should cut administrative burden and program costs while increasing revenue.