AHPA submitted a comment letter on: 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.

Click here for the full comment letter. Some takeaways below:

• Protect physician reimbursement and avoid further payment reductions:
  AHPA urges CMS to maintain current payment levels and avoid additional reductions through changes to Relative Value Units, warning that continued cuts could threaten provider viability, reduce patient access, and limit investments in maternal health, chronic disease prevention, and health-related social needs.
• Permanently preserve and expand Medicare telehealth flexibilities:
  AHPA supports continued coverage of audio-only services, virtual direct supervision, provider home-address protections, and telehealth options for opioid use disorder treatment. It also recommends permanently eliminating arbitrary frequency limits and relying instead on targeted program-integrity oversight.
• Modernize and strengthen Medicare primary care payment:
  AHPA supports advanced primary care management and hybrid payment models but recommends that CMS build on models already tested by the Center for Medicare and Medicaid Innovation, increase primary care reimbursement, reduce administrative burdens, provide technical assistance, and avoid reforms that would trigger further conversion-factor reductions.
• Strengthen the Medicare Shared Savings Program while reducing administrative burden:
  AHPA supports the proposed Health Equity Benchmark Adjustment, reopening of ACO payment determinations, simplified beneficiary notifications, and prepaid shared savings. However, it recommends expanding ACO eligibility for the health equity adjustment and providing ACOs greater flexibility in how prepaid shared savings may be used.
• Expand Medicare reimbursement for addressing health-related social needs:
  AHPA recommends reimbursing additional diagnosis codes and services related to housing, food insecurity, transportation, care management, and discharge planning. It also urges CMS to cover these services regardless of whether they are delivered virtually or in person and to support community-based organizations that receive patient referrals.