NCHA Submits Comment Letter on Physician Fee Schedule Proposed Rule for CY 2020

NCHA submitted the attached comment letter addressing the Physician Fee Schedule proposed rule for Calendar Year 2020. Specifically, NCHA supported the Centers for Medicare & Medicaid Services’ proposals to reverse previously finalized policies for evaluation and management payments that threaten access to care for vulnerable populations. We expressed concern with CMS’s proposed criteria for therapy assistant services and the proposal to price Part B injectable and implantable drugs in the opioid treatment program bundle using the average sales price without the legally mandated 6% add-on.