RE: Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment
Model Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment
Models
Dear Acting Administrator Slavitt:
The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty physicians
from 13 specialty and subspecialty societies. The Alliance is deeply committed to improving access to
specialty medical care through the advancement of sound health policy. For this reason, we are
pleased to provide input that will inform your implementation of the provisions outlined in the
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA); specifically, the Medicare Quality
Payment Program (QPP), including the Merit-Based Incentive Payment System (MIPS) and alternative
payment models (APMs).
General Sentiments on the Medicare Quality Payment Program
Member organizations of the Alliance have continuously sought out and developed robust
mechanisms, including clinical decision support, clinical data registries, and other tools aimed at
improving the quality and efficiency of care specialty physicians provide. In addition, Alliance member
organizations have analyzed and heavily scrutinized data related to the services they provide, looking
for ways to improve how they diagnose, treat, and manage some of the most complex healthcare
conditions in their respective specialty areas. With those sentiments in mind, the Alliance is eager to
engage in programs that would further these efforts with incentives and technical assistance.
…
Read full letter here
