Every July, CMS releases a draft proposal describing the changes that they are proposing for the following year’s Physician Fee Schedule (PFS). After a comment period to collect public feedback, CMS finalizes the rule in November for implementation the following January. We are proud of the Michigan Multipayer Steering Committee’s comment letter submission which featured the following reflections on the proposed 2027 PFS rule and on the questions posed in their query for guidance on evolving primary care payment models:
- Using a CMMI demonstration to test waiving patient cost-sharing for Advanced Primary Care Management (APCM) Codes and Add-On Behavioral Health Integration (BHI) codes in the near term while doing the work to enable cost-sharing for all key care management codes (e.g., Chronic Care Management (CCM), Principal Care Management (PCM), Transitional Care Management (TCM), and Advanced Primary Care Management (APCM)).
- Converting G2211 to a modifier with two levels (one for clinicians in MSSP and one for those who are not) as a constructive change that rewards both complex and longitudinal care while preferentially rewarding participation in accountable care.
- Creating a new code or mechanism specific to rewarding the work associated with longitudinal primary care.
- Exempting APCM expenses from ACO benchmarking.
- Retaining the Person-Centered Primary Care Measure (PCPCM).
- Continuing the progress made to date to evolve Traditional Medicare primary care payment into a hybrid model and refine hybrid and capitated primary care approaches in managed Medicare approaches.
We are also happy to say that the Michigan Multipayer Initiatives comment letter reflects many of the themes of the comments on the 2027 proposed CMS PFS submitted by the National Academy of Science, Engineering, and Medicine’s Standing Committee on Primary Care.
