NPC Submits Comments on Medicare Physician Fee Schedule Proposed Rule

NPC submitted comments on the Medicare Program’s CY 2022 Physician Fee Schedule proposed rule recommending opportunities to enhance understanding of patient-reported outcomes and address barriers to medication access.

The National Pharmaceutical Council (NPC) submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Medicare Program’s CY 2022 payment policies under the Physician Fee Schedule and other policy changes (“CY 2022 PFS Proposed Rule”). The CY 2022 PFS Proposed Rule policies for physician quality programs affect measurement and improvement of care delivery and health outcomes for Medicare beneficiaries and can impact patients’ access to innovative therapies. NPC’s comments support CMS’ continued efforts to improve quality measurement, promote patient-centered care, and focus on health equity. We further recommend opportunities to enhance understanding of patient-reported outcomes and address barriers to medication access.

NPC has conducted research in partnership with Discern Health and the Pharmacy Quality Alliance (PQA) on key topics addressed in the proposed rulemaking such as development and integration of meaningful patient-reported outcome measures, priorities for value-based payment, and gaps in quality measurement. This research provided the foundation for NPC to offer comments on the following:

  • Prioritizing the advancement of patient-reported and other cross-cutting measurement gap areas (e.g., access to specialists and nonphysician clinicians) when expanding its digital quality measurement portfolio.
  • Supporting the use of patient-centered quality measures and activities in the Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs), including cross-cutting measures, patient-reported performance measures, and measures addressing barriers to medication access.
  • Promoting the use of patient-reported measures in the traditional MIPS program, including measures that assess goal setting, shared decision-making, and care concordance with treatment plans.
  • Recommending development of MIPS improvement activities with a more holistic approach to increasing medication access that considers medication challenges and the overall value of treatment.

The full NPC comment letter can be found here. More information about CY 2022 PFS Proposed Rule can be found here.

For additional information, check out NPC’s research with Discern Health and PQA: Improving Patient-Reported Outcomes in Oncology, Improving Oncology Quality Measurement in Accountable Care, Accountable Care Measures for High-Cost Specialty Care and Innovative Treatment, Access to Care: Development of a Medication Access Framework for Quality Measurement and Shared Decision-Making and Value-Based Care Research Featured at PQA Annual Meeting.