CMS’ Payment Reg: Promising Policies, but Tied to a Flawed System

Better Health – NOW Campaign to Submit Comment

On July 1st CMS released several constructive new proposals in its annual Medicare Part B payment Notice of Proposed Rulemaking. Provisions include

  • New flexibilities to support behavioral health integration in primary care;
  • Advanced Investment Payments to form ACOs in underserved communities;
  • A series of steps to help make the Medicare Shared Savings Program better for practices  overall and particularly in underserved communities;
  • Coverage for medically necessary dental care in Medicare for beneficiaries with certain conditions.

Unfortunately CMS’s helpful proposals remain rooted in a predominantly fee-based framework that under-resources primary care and fails to support health equity. Across-the-board reductions to Medicare Part B practices, now looming January 1st, further underscore the urgent need for new solutions.

Working with Better Health – NOW Campaign participants, the PCC team is developing comments that support worthwhile CMS proposals, while urging bolder reforms aligned with our Concordance Recommendations for Primary Care Investment and Payment. Draft comments will be circulated for feedback from Better Health – NOW Campaign Participant organizations by mid-August.  If your organization is not yet a Better Health – NOW Campaign Participant, now is a great time to get engaged. Please contact to learn how.

PCC encourages Executive Members to consider submitting their own comments to CMS. Comments are due to CMS 11:59 pm Tuesday, September 6th.

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