RE: CMS-5522-P, Medicare Program, CY 2018 Updates to the Quality Payment Program, 42 CFR Part
414
Dear Ms. Verma,
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 inform your implementation of Year 2 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 Year 2 Proposals for the Medicare Quality Payment Programs
We greatly appreciate the considerable flexibility and incentives for small practices CMS incorporated
into its proposed policies for Year 2 of the QPP, many of which will benefit specialty physicians.
Nevertheless, we continue to believe specialists 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 specialists will expend to engage in the program. This is
particularly true now that only 37 percent of professionals billing under Medicare Part B are expected to
be included in MIPS.
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