Advocacy Correspondence: CMS Comment letter, CMS-1807-P Medicare Physician Fee Schedule Proposed Rule CY 2025
September 9, 2024
The Honorable Chiquita Brooks-LaSure
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Attention: CMS-1807-P
P.O. Box 8016
Baltimore, MD 21244-8016
RE: CMS-1807-P. Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments; Proposed Rule, July 31, 2024
Dear Administrator Brooks-LaSure:
On behalf of The Hospital and Healthsystem Association of Pennsylvania (HAP), which represents approximately 235 member hospitals, we appreciate the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) Medicare Physician Fee Schedule proposed rule for calendar year (CY) 2025.
HAP is deeply concerned that CMS’ proposed payment rate will substantially reduce payments from their current level posing significant risk to patient’s access to care and health systems’ financial stability, particularly for safety net providers.
However, HAP is pleased to see the agency’s continued efforts to retain important telehealth flexibilities permitted during the COVID-19 pandemic as well as the delay in implementing the proposal to change how a split visit is defined. However, we are critically concerned with services at risk for disruption baring Congressional action.
In addition, we incorporate, by reference, all the comments provided in the American Hospital Association’s response to the proposed rule.
Thank you for your consideration of HAP’s comments regarding this proposed rule. If you have any questions, contact me at (717) 561-5317.
Sincerely,
Kate Slatt
Vice President, Policy and Care Delivery
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Topics: Access to Care, Behavioral Health, Federal Advocacy, Medicare, Telehealth
Revision Date: 9/9/2024
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