CSM put out its Physician Fee Schedule Final Rule on Oct. 30, including changes to its Quality Payment Program/ Merit-based Incentive Program (QPP/MIPS) and Medicare Shared Savings Program. Readers of our physician practice management weekly would be interested to know more about those two sections: QPP: - Will the MVP changes increase adoption? - Will the push to quicker risk -- the shorter rise-free path, 5,000 assigned beneficiary flexibility, etc. -- make a difference? What else could/should they be doing? - Anything noteworthy in the topped-out and administrative claims benchmarking changes? - Are any of the RFIs (request for information) potentially interesting? - Anything under-noticed in this rule that you’d like to call out? Shared Savings: How does the change in beneficiary eligibility for Medicare CQMs promotes “greater overlap with the ACO's assignable beneficiary population"? CMS will “include complementary behavioral health integration and psychiatric Collaborative Care Model services to the definition of primary care services" and says this "might increase participation in the Shared Savings Program…” How would it do this? -CMS changes on its proposal to drop G0136 as an attributable primary care service. Any idea why they changed their minds? - Anything under-noticed here you’d like to call out?

I run a subspecialty teleradiology practice that works with hospitals and imaging centers nationwide, so I see how reimbursement changes ripple through to what facilities can afford and how they staff coverage. I'm not a policy wonk, but I've been on the ground during every CMS shift since launching South Florida Radiology in 2020, and these changes directly affect whether hospitals can justify bringing in specialists like pediatric radiologists. The MVP changes won't move the needle much for small practices like mine because the reporting burden is still too heavy relative to our scale--we're physician-owned with lean operations, not a big health system with compliance staff. The 5,000 beneficiary threshold flexibility might help mid-sized groups enter risk arrangements, but honestly most independent radiologists I know are too stretched covering clinical demand (we've been adding states every quarter) to take on capitated models. CMS should streamline the quality measures to what actually impacts diagnostic accuracy--like critical result communication turnaround time--instead of administratively intense box-checking that doesn't change patient outcomes. On Shared Savings, adding behavioral health integration to primary care definitions makes sense because pediatric radiology often intersects with psych cases--think non-accidental trauma imaging or eating disorder complications we see in children's hospitals. If an ACO can now attribute those kids under integrated behavioral models, it gives hospitals like Children's Hospital of the King's Daughters (one of our partners) more reason to invest in comprehensive care coordination, which includes timely subspecialty reads. When volume dropped 30% during COVID, the facilities that survived were the ones with diversified service lines and value-based contracts buffering fee-for-service swings. CMS probably kept G0136 because dropping it would've gutted attribution for rural and telehealth-heavy practices--during the pandemic, virtual primary care exploded and removing that code would've penalized exactly the access models CMS claims to support. What's under-noticed is that none of these tweaks address the radiologist shortage in subspecialties; we're adding partnerships because demand for pediatric coverage far outpaces supply, but reimbursement models still don't incentivize training more fellows or retaining them in underserved markets.

CMS finally expanded the Shared Savings definition of primary care to include behavioral health integration. This is a real win for organizations like ours that are trying to blend mental and physical health, since our services now count more toward attribution. They also reversed course on G0136, which makes it clear they're actually listening to what providers have been saying about service alignment.