Dear Administrator Verma:
On behalf of the undersigned organizations, we urge the Centers for Medicare & Medicaid Services (CMS)
to reduce the 2018 Merit-based Incentive Payment System (MIPS) quality measure reporting period from a
calendar year to a minimum of 90 consecutive days due to the lack of timely and direct notification by CMS
on whether a physician is considered MIPS eligible, as well as a severe delay by CMS in updating the
Quality Payment Program (QPP) interactive website with 2018 information. It is our understanding that
CMS does not plan to update the QPP website with 2018 information and measures until the summer, at the
earliest. Furthermore, we request a reduced reporting period for future MIPS program years in order to
reduce administrative burden and ensure physicians have sufficient time to report after receiving
performance feedback from CMS.
While we recognize CMS posted eligibility information on the QPP website on April 6, 2018, we are
concerned with physicians’ ability to satisfactorily participate in the MIPS program due to the late
notification. Several policy changes in 2018 from 2017 complicate physicians’ ability to determine their
MIPS eligibility status. For example, CMS expanded the 2018 low-volume threshold exemption. While the
undersigned organizations strongly support the increased low-volume threshold and believe it will assist
small practices and physicians who treat a small number of Medicare patients, it may create changes in
physicians’ eligibility status.
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