Subject: Medicare Program; Merit-Based Incentive Payment System (MIPS) and
Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule,
and Criteria for Physician-Focused Payment Models (CMS-5517-P)
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 comment on the above-referenced proposed Medicare physician fee
schedule rule implementing the new Merit-Based Incentive Payment System (MIPS) and Alternative
Payment Models (APM) quality payment programs. The AANS and CNS recognize the complexity of the
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), and we appreciate the agency’s
efforts to develop a new payment system that provides physicians with greater flexibility while at the
same time minimizing the reporting burden.
We remind CMS that organized neurosurgery continues to develop tools to help neurosurgeons adopt
and incorporate systems of learning into their practice to improve quality of care, provider workflow,
patient safety and efficiency. Our national clinical registry, the Quality and Outcomes Database (QOD)
— which was approved by CMS as a Qualified Clinical Data Registry (QCDR) for the past two years — is
one way in which we are working to capture this information and adopt systems that will improve the
value of our services. The QOD allows for prospective, systematic tracking of practice patterns and
patient outcomes that will allow neurosurgeons to improve the quality, efficiency and, ultimately, the
value of care.
…
Read full letter here
