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 continue to inform your
implementation of the Merit-based Incentive Payment System (MIPS) and Alternative Payment
Models (APMs) under the Quality Payment Program (QPP) established as part of the Medicare
Access and CHIP Reauthorization Act of 2015 (MACRA).
General Sentiments on the Medicare Quality Payment Program
We greatly appreciate the considerable modifications CMS incorporated into its finalized
policies under the QPP, particularly with regard to the “Pick Your Pace” reporting strategy and
reweighting of the MIPS performance categories in the first performance year. Nevertheless,
we continue to believe specialty physicians will struggle with the reporting and performance
requirements, primarily under the MIPS, and that patient health and outcomes will not
significantly improve commensurate with the time and effort providers expend to engage in the
QPP.
We are also concerned that CMS continues to treat the MIPS program as four separate
programs with different requirements and complex scoring mechanisms. CMS must work to
streamline the MIPS, integrating the performance categories into a more cohesive program,
and simplify the scoring, so it is well understood by participants.
…
Read full letter here
