Re: Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM)
Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment
Models; Proposed Rule (CMS-5517-P)
Dear Acting Administrator Slavitt:
On behalf of the undersigned organizations, thank you for the opportunity to comment on the notice of
proposed rulemaking (NPRM) regarding the implementation of MIPS and APMs under the Medicare
Access and Chip Reauthorization Act (MACRA). The undersigned state, national, and specialty medical
societies represent the vast majority of practicing and future physicians who provide medical services
every day for millions of patients. We appreciate the administration’s outreach to the physician
community during the comment period on this important proposed rule, including listening sessions,
briefings, and meetings with our organizations. We are especially thankful for the statements from the
Centers for Medicare & Medicaid Services (CMS) about the importance of identifying NPRM policies
that need to be modified to avoid adopting perverse incentives or creating barriers to successful
participation. We remain hopeful that this ongoing dialogue with medicine will promote the effective
implementation of MACRA. While some progress has been made in the regulation, the physician
community remains very concerned about a number of the proposed rule provisions
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