The Alliance of Specialty Medicine (“Alliance”) is a coalition of fifteen medical specialty
societies representing more than 100,000 physicians and surgeons from specialty and
subspecialty societies dedicated to the development of sound federal health care policy that
fosters patient access to the highest quality specialty care. As patient and physician advocates,
the Alliance welcomes the opportunity to provide input in the formulation of healthcare and
Medicare policy. This hearing is an important step toward continuing the promise of the
Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and associated programs
established under the Centers for Medicare and Medicaid Services’ (CMS) Quality Payment
Program (QPP) – the Merit-based Incentive Payment System (MIPS) and Advanced Alternative
Payment Models (A-APMs) – as it was intended by the Congress.
The Alliance of Specialty Medicine believes:
- Congress should continue to make adjustments to the programs created under MACRA;
- Congress should maintain a viable fee-for-service option for providers under the
Medicare program; - Congress must safeguard beneficiaries’ access to care by eliminating the 0% payment
update applied to the Medicare conversion factor from 2020 – 2025 and replacing it with
an update factor that better recognizes the Medicare Physician Fee Schedule conversion
factor has failed to keep with inflation and in some instances has been reduced. - Congress should acknowledge the slow pace of implementation of APMs by altering the
timelines for bonuses embedded in statute. This includes:
o Extending the availability of the Advanced APM 5% Incentive Payment in
acknowledgement of the snail’s pace of APM implementation by Medicare; and
o Re-evaluating the qualifying participation thresholds for the A-APM incentive
payment in light of the lack of implementation by CMS of qualifying APMs
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