Andrew M. Slavitt
Acting Administrator, Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-3321-NC
Submitted electronically via http://www.regulations.gov
RE: Request for Information Regarding Implementation of the Merit-Based Incentive Payment
System, Promotion of Alternative Payment Models, and Incentive Payments for Participation
in Eligible Alternative Payment Models
Dear Acting Administrator Slavitt:
As the Alliance of Specialty Medicine (Alliance), our mission is to advocate for sound federal health
policy that fosters patient access to the highest quality specialty care. We are writing today to provide
input that will inform your implementation of the newly established Medicare physician payment
models described in the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015.
Merit-Based Incentive Payment System (MIPS)
The Alliance urges CMS to make significant improvements to its existing quality improvement initiatives
as they are consolidated into the new MIPS program.
We make the following recommendations for the quality component:
- At a minimum, maintain the currently available reporting mechanisms to ensure all eligible
professionals can report quality data. - Adopt policies that promote investment in Qualified Clinical Data Registries (QCDR),
interoperability between QCDRs and electronic health records (EHR), and permit eligible
professionals to meet the quality component of MIPS by participating in a QCDR
o Use of a QCDR should also count toward any meaningful use requirements related to
quality reporting - Support the development high-quality and relevant measures for specialists and expand the
availability of specialty-focused quality measures to ensure all specialty and subspecialties have
a fair opportunity to demonstrate quality improvement for the conditions and populations they
treat - Use the National Quality Strategy (NQS) domains only as a guide, rather than a reporting
requirement. If this is not immediately possible, CMS should at least permit the assignment of
individual measures to multiple domains. - Adopt outcomes measures as they become available, but maintain balance in performance
weighting so that eligible professionals without appropriate outcomes measures are not unduly
penalized
…
Read full letter here
