Dear Acting Administrator Slavitt:
Thank you for the opportunity to provide input to the Request for Information (RFI) regarding the
implementation of Alternative Payment Models (APMs) and Merit-Based Incentive Programs (MIPS)
under the Medicare Access and Chip Reauthorization Act (MACRA). We appreciate the
Administration’s willingness to prioritize the issues in the RFI that need to be addressed and to extend the
comment period. Both of these adjustments will allow the physician community to provide the
administration with more thoughtful input. We also appreciate that the Administration held listening
sessions on these topics. We are hopeful that an ongoing dialogue with medicine will promote smooth
and successful implementation of MIPS and APMs.
The physician community was deeply engaged while Congress drafted MACRA. We believe that, if
properly implemented, the new physician payment framework will promote improvements in the delivery
of care for Medicare patients. To help physicians make the transition to new care and delivery models
and assure access to high-quality care for all patients, the undersigned organizations urge the
Administration to carefully consider and adopt principles that:
- Support delivery system improvements. Constraints and limitations of current payment systems that obstruct physician-identified improvements in care must be eliminated. In addition, requirements for new models should be flexible enough to support different organizational arrangements and patient population needs so that innovation can flourish.
- Avoid administrative and cost burdens for patients. Patients should not be unduly burdened with hidden costs, administrative requirements or other obstacles that discourage them from seeking care or fulfilling their treatment plans.
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