Subject: Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative
Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for PhysicianFocused Payment Models (CMS-5517-P)
Dear Administrator Slavitt:
The Council of Medical Specialty Societies (CMSS), with 43 member societies representing 790,000
physician members in the US, is pleased to comment on the proposed rule for MIPS and APMs. We
will comment in several categories. Should you have any questions, please do not hesitate to
contact us.
Timeline for Implementation
We hope that CMS already recognizes that an implementation timeline of January 1, 2017 is too
aggressive. We suggest that the performance period start on July 1, 2017 to allow time for
adequate physician education and preparation for the transition to this fundamentally new payment
system.
Moreover, the 2-year data lag between performance measurement and payment adjustments
seems to be more of a reward and punishment system than a value-based payment
system. Without rapid cycle feedback and an ability to connect behavior to payments, physician
practices are challenged to improve their delivery of value-based care.
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Read full letter here
