Comment Letter

AANS and CNS Oppose Development of Flawed Quality Measures

  • Quality Improvement and Patient Safety

Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore MD 21244

Submitted electronically to

Subject: Draft 2025 MVP Candidate Feedback

To whom it concerns:

On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we appreciate the opportunity to comment on the 2025 candidate Merit-Based Incentive Payment System (MIPS) Value Pathways (MVPs). Our comments below focus on the Surgical Care MVP.

Our primary concern with the Surgical Care MVP is that it attempts to lump numerous unrelated surgical specialties (e.g., general surgery, neurosurgery, cardiac surgery, breast surgery) into a single MVP. This is inappropriate from a clinical perspective and provides little added value — beyond the current MIPS specialty quality measure sets — in terms of assisting surgical specialists with identifying the most relevant MIPS measures. According to the Center for Medicare & Medicaid Services (CMS) MVP guiding principles, “MVPs should consist of limited, connected, complementary sets of measures and activities that are meaningful to clinicians, which will reduce clinician burden, align scoring, and lead to sufficient comparative data.” As currently constructed, this MVP will not satisfy any of those goals. Instead, it will create confusion and discourage movement into MVPs among surgeons, who might assume that CMS plans to evaluate their performance against other unrelated surgical specialties, pitting one specialty against another.

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