Subject: Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM)
Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused
Payment Models: Final Rule with Comment Period (CMS-5517-FC)
Dear Administrator Slavitt:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), representing over 4,000 neurosurgeons in the United States, we
appreciate the opportunity to provide additional feedback on the new Medicare Quality Payment Program
(QPP) outlined in above referenced final rule published in the Federal Register in October. The AANS
and CNS recognize that implementing the Medicare Access and CHIP Reauthorization Act of 2015
(MACRA) is a challenging task. And while we greatly appreciate the agency’s decision to adopt a
transition year that allows increased flexibility and minimizes administrative complexity, we still have
serious concerns about the underlying policies driving this program and the impact some of these
policies will have on practicing physicians following the 2017 transition year.
GENERAL COMMENTS
The AANS and CNS appreciate that the Centers for Medicare & Medicaid Services (CMS) adopted a
strategy whereby physicians will have the flexibility to participate in the Merit-based Incentive Payment
System (MIPS) during the 2017 performance year at a pace that best matches the readiness of their
practices. Those who contribute minimal effort will still be protected from penalties, while those who feel
prepared to report more robustly will have the opportunity to be recognized for their investment and to
earn larger bonus payments. This includes reporting measures and activities for as little as 90 days or
as long as the calendar year. We also appreciate that CMS recognized the limitations of current
physician resource use measures by assigning a weight of zero to the cost category and by not holding
physicians accountable for these metrics during the initial year of MIPS. Furthermore, we appreciate that
per our suggestions, CMS:
…
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