Comments Due Next Week on CY 2027 PFS Proposed Rule

The Centers for Medicare and Medicaid Services (CMS) has issued its Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP).

The CY 2027 PFS Proposed Rule includes proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Specifically, CMS is proposing policies that:

• Move toward the full implementation of MIPS Value Pathways (MVPs).

• Focus on prevention and wellness in patient care.

• Reduce administrative burden.

• Promote more meaningful participation that drives quality and value.

2027 Policy Proposal Highlights

Key QPP policies that CMS is proposing in the CY 2027 Medicare PFS Proposed Rule include:

• Sunsetting the traditional MIPS reporting option after the 2028 performance year.

• Introducing three new MVPs for the 2027 performance year that are related to diabetic disease, hypertension, and hospitalists, and modifying all 27 previously finalized MVPs.

• Replacing the outcome/high-priority measure requirement for the quality category with a new MIPS core measure requirement.

• Revising the MIPS Promoting Interoperability performance category reporting requirements in the CY 2026, 2027, and 2028 reporting periods.

• Modifying the APM Performance Pathway Plus (APP Plus) quality measurement set and introducing a new collection type: Medicare Electronic Clinical Quality Measures for Accountable Care Organizations Participating in the Medicare Shared Savings Program (Medicare eCQMs).

• Applying Qualifying APM Participant (QP) and Partial QP determinations at the Taxpayer Identification Number/National Provider Identifier (TIN/NPI) level instead of the NPI level.

Overview of RFIs

CMS is also seeking feedback on RFIs about the following topics:

• The future transition to FHIR-based digital quality reporting for QPP including the overall transition timeline, key milestones, and implementation considerations.

• Whether CMS should consider MVP score normalization within an MVP to ensure scoring fairness across MVPs.

• Improvements and alternative options to the current Star rating assignment methodology for Quality Measure scores collected under the administrative claims collection type.

Comment on the CY 2027 Proposed Rule

The proposed rule includes directions for submitting comments within the 60-day comment period. Comments must be submitted by Sept. 14.

When commenting, refer to file code: CMS-1848-P

No FAX transmissions.

Use one of the three following ways to officially submit comments:

• Electronically: regulations.gov

• Regular mail: Centers for Medicare and Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, P.O. Box 8016, Baltimore, MD 21244-8016.

• Express or overnight mail: Centers for Medicare and Medicaid Services, Department of Health and Human Services, Attention: CMS-1848-P, Mail Stop C4-26-05, 7500 Security Boulevard, Baltimore, MD 21244-1850.

Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.