AHA to MedPAC Re: Physician Fee Schedule Payments, A-APM Incentives and Medicare Advantage Network Adequacy

December 9, 2024

Michael Chernew, Ph.D.
Chairman
Medicare Payment Advisory Commission
425 I Street, NW, Suite 701
Washington, D.C. 20001

Dear Chairman Chernew:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations; our clinician partners - including more than 270,000 affiliated physicians, 2 million nurses and other caregivers - and the 43,000 health care leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to share our comments regarding the Medicare Payment Advisory Commission (MedPAC) November meeting sessions related to physician fee schedule payments, advanced alternative payment model (A-APM) incentives and Medicare Advantage (MA) network adequacy.

In particular, we:

• Directionally support updates to physician reimbursement that are tied to the Medicare Economic Index (MEI) but maintain that the discussed factor of MEI minus 1 is not nearly sufficient to make up for the existing shortcomings in physician reimbursement.
• Oppose penalizing facility-based providers by reducing their reimbursement rates. Doing so is not only inappropriate, but also would create an even greater incentive for physicians to seek out employment from other entities, such as private equity firms and health insurers (which have acquired the vast majority of physician practices during the last five years).
• Support an extension of the A-APM incentive payments.
• Encourage the commission to examine the impact of the inadequate MA post-acute care network requirements on beneficiaries' access to care.

Our detailed comments on these issues follow.