Association Comments on CY 2027 PFS Proposed Rule

America's Essential Hospitals responded on Sept. 14 to the Centers for Medicare & Medicaid Services' (CMS') proposed annual update to the Physician Fee Schedule (PFS) and other major policies. The association urged CMS to support essential hospitals through the creation of an essential hospital designation and additional adjustments to the proposed rule.

Specifically, the association urged the agency to:

• Strengthen incentives across the Medicare Shared Saving Programs (MSSP) BASIC Track to allow essential hospital-based accountable care organizations to enter MSSP and gradually take on greater risk
• Finalize its proposal to increase the prior savings adjustment for MSSP
• Finalize its proposal to risk-adjust the 5% cap on upward adjustments to the historical benchmark in the MSSP
• Withdraw the proposed cut for some evaluation and management procedures
• Delay implementation of significant adjustments for the practice expense methodology
• Protect the 340B Drug Pricing Program by withdrawing the proposed mandatory reporting requirements until it has completed meaningful voluntary testing and evaluated the repository's accuracy

America's Essential Hospitals further used the comment period to advocate for the creation and use of an essential hospital designation to protect providers of essential health services.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.