The Steering Committee of Michigan Multipayer Initiatives (MMI) is a collective group of leaders that represent primary care practices, Physician Organizations, payers, and community-based organizations. Recently, in response to a Request for Information (RFI) that CMS included in the 2025 proposed Physician Fee Schedule (PFS) release, the MMI Steering Committee worked together to put the interest of patients above the interest of individual organizations. Their comments on the proposed 2025 PFS and response to the RFI on primary care design reaches for the higher goal of the kind of comprehensive, whole-person, coordinated care we would all like to receive. Here is a summary of some of the recommendations that it contained on key elements of the RFI:
On Streamlining Value-Based Care Opportunities
We encourage continuation of the use of MSSP ACO as a vehicle to differentially reward providers who succeed in delivering whole-person care.
We encourage CMS to permit ACOs to waive beneficiary cost-sharing when members obtain services from ACO providers, especially for primary care services. This could function as a helpful incentive to keep providers in value-based arrangements.
Measures and metrics for primary care should be proportional to their sphere of influence.
We strongly support properly valuing primary care services. Real progress requires creating separate fee schedules (cognitive and procedural) and restoring the RUC to an advisory role.
On Billing Requirements
The cost-sharing requirement for APCM services will be problematic to engaging providers in its use. Commercial payers in our state have honored feedback from care managers about this concern and have freed cost-sharing from being a roadblock to care management engagement. Though we understand the statutory restrictions that CMS faces, we do believe that CMS has the authority to permit the exclusion of cost-sharing where there is allowance for program flexibility (e.g., excluding cost-sharing for primary care services when patients seek primary care services from ACO providers, etc.).
On Supporting Person-Centered Care
Further streamline measure and metric expectations for primary care.
We note with interest CMS’ inclusion of the Person-Centered Primary Care Measure Patient Reported Outcome Performance Measure (PCPCM PRO-PM) and believe it to be a promising tool.
On Supporting Health Equity
We share CMS’ emphasis on the pursuit of health equity. Some Michigan payers have begun to adjust for social complexity via the Area Deprivation Index (ADI). We do think that adjusting on the basis of patient residence, not provider location, leads to more equitable allocation of resources. Our practices desire to support patients with social needs but believe that connection to community is key. Community-based organizations (CBOs) have the experience and expertise to help patients navigate and address health-related social needs and we believe that CBOs can only do this with appropriate resources and funding.
On Quality Improvement and Accountability
We believe that CEHRT technology is an important enabler to optimize the use of data for coordination and optimization of care. Instead of additional requirements on practices, however, we instead encourage CMS to focus on common expectations and requirements of EHR vendors. This is especially important so that primary care practices are not held hostage by them.
In closing, we applaud CMS’ hard work and earnest effort to incorporate and implement the National Academy’s recommendations into the 2025 PFS and note with appreciation the thoughtfulness with which they have been proposed. We are, however, concerned about the impact of cost-sharing on restricting provider uptake of the codes, and encourage interagency action and coordination. We believe that the new APCM codes could be a gateway for real change and adoption by other payers. We also encourage CMS to watch developments in states (e.g., California) that are experimenting with comprehensive hybrid payment as you further explore additional hybrid payment reform.
Michigan Multipayer Initiatives 