Advocacy to Strengthen Medicare

PAI actively promotes Medicare policies that sustain and improve this critically important health insurance program for our nation’s seniors, asking that Congress and HHS and other federal regulators: 

• Develop programs and test models that support independent physician practices’ ability to coordinate and deliver high quality services to Medicare patients under “value-based payment” systems, including Medicare’s Quality Payment Program (QPP);  
• Deliver on the promise of regulatory relief, eliminating duplicative and unnecessary regulations that increase costs for physician practices; 
• Ensure a fairer and more streamlined audit process, including an affordable, timely and fair appeals process; and 
• Adopt policies that eliminate the artificial payment incentives to deliver services in hospital-owned settings over less costly settings, including physician offices.

PAI Advocacy Initiatives​

• PAI Recommendations to CMS on Reducing Administrative Burden to Put Patients Over Paperwork
  PAI submitted comments in response to CMS’s Request for Information (RFI) on Reducing Administrative Burden to Put Patients Over Paperwork.  PAI supports CMS efforts to reduce administrative burden and encourages the Agency to adopt policies that help optimize time spent in physician-patient encounters, including those on prior authorization, Network Adequacy, Recovery Audit Contractors (RACs) and to streamlining and align federal and state requirements relating to Medicare and Medicaid.
• PAI Letter to CMS Commenting on 2019 Physician Fee Schedule
  PAI offers a series of recommendations on the 2019 physician fee schedule, including recommendations to strengthen the QPP to make it less onerous for physician practices.
• PAI Letter to CMS Commenting on 2019 OPPS Payment Rule and Release
  PAI’s letter to CMS supports proposed payment changes for off-campus provider-based departments (OC-PBDs) that reflect the goal of evolving to site-neutral Medicare payments, reversing policies of higher payments for the same services delivered in hospital outpatient settings over the physician office setting.  
• PAI Letter to CMMI on Direct Provider Contracting Model
  PAI lauds CMMI for seeking input on DPC models, which if implemented carefully would provide physicians with an opportunity to engage in innovative payment models as they coordinate and deliver health care services for certain patient populations.  
• PAI Part B Demonstration Letter
• On October 5th, PAI submitted a comment letter in response to the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS) and Quality Payment Program (QPP) Proposed Rule published by CMS in August of this year. PAI provided extensive feedback on several changes and flexibilities proposed by the Agency, concerning both COVID-19 and non-COVID-19 related issues.
• PAI Letter to CMS Commenting on Proposed 2022 Medicare Physician Fee Schedule
  PAI's letter includes recommendations to maintain the 3.75% payment adjustment increase to avoid drastic payment cuts to physicians as they continue to struggle through the pandemic; permanently finalize certain telehealth flexibilities; and avoid drastic changes to the MIPS track of the Quality Payment Program.
• PAI Submits Comment Letter in Response to 2025 MPFS and QPP Proposed Rule
  On September 9, PAI submitted a comment letter (PDF) in response to CMS’ Calendar Year (CY) 2025 MPFS and QPP Proposed Rule. PAI strongly opposes the continued payment cuts for CY 2025 as a result of the proposed reduced conversion factor (CF). PAI underscored how the proposed rule fails to account for inflation in medical practice costs and the impact that cuts have on Medicare beneficiaries' access to care and continued consolidation. For more information, click here.