APG Responds to CMS CY 2021 Medicare Physician Fee Schedule Proposed Rule

Washington, DC – America’s Physician Groups (APG) submitted comments on the CY2021 Medicare Physician Fee Schedule to the Centers for Medicare & Medicaid Services (CMS), outlining its recommendations on the proposed revisions to payment policies, payment rates, and other provisions under the Medicare Part B program. APG’s comments address the proposed changes in the Medicare Shared Savings Program (MSSP), telehealth services, scope of practice, and care management services.

“On behalf of the nation’s physicians providing valued-based care, APG appreciates the opportunity to provide CMS with input on these proposed changes to the 2021 Medicare Physician Fee Schedule,” said Don Crane, APG President and CEO. “Our members believe that any proposed changes should serve to strengthen patient care, set appropriate quality performance measures, and expand access to telehealth.”

Some summary highlights from the letter:


  • Recommend continuing to utilize the Web Interface reporting for another year while phasing in a new quality reporting system to give ACOs sufficient time to implement a new reporting method
  • Recommend maintenance of the APM Scoring Standard and delay implementing the proposed APP until 2022
  • Recommend CMS implement another method of setting benchmark such as a blend of previous year quality scores rather than using the performance year to set the benchmark

Telehealth and Other Services Involving Communications Technology

  • Recommend expanding audio-only telehealth services under Communication Based Technology Services with adequate reimbursement

Care Management Services and Remote Physiologic Monitoring Services

  • Recommend consideration of removing the self-reported data restriction due to the realities of patients’ relationships with technology
  • Support CMS’ view that payment for RPM for both chronic and acute conditions is appropriate and agree with the proposal as it currently stands

Read the full letter here.

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About America’s Physician Groups

America’s Physician Groups is a not-for-profit, mission-driven association organized to assist accountable physician groups to improve the quality and value of healthcare provided to patients. America’s Physician Groups represents and supports physician groups that assume responsibility for clinically integrated, comprehensive, and coordinated healthcare on behalf of our patients. In California, APG represents over 180 physician groups across the state. Visit us at www.apg.org.

Contact: Greg Phillips, APG Director of Communications, 202-770-1901, gphillips@apg.org