RE: Innovation Center New Direction – Request for Information
Dear Ms. Verma,
The Alliance of Specialty Medicine (the “Alliance”) represents more than 100,000 specialty
physicians from thirteen specialty and subspecialty societies. The Alliance is deeply committed
to improving access to specialty medical care through the advancement of sound health policy.
On behalf of the undersigned members, we are pleased to respond to your request for
information on the agency’s planned new direction for the Innovation Center.
Guiding Principles
The Alliance is encouraged about the prospect of a new direction for the Innovation Center.
While we agree that CMS’ existing partnerships with healthcare providers, clinicians, states,
payers, and stakeholders have generated important value and knowledge, specialty physicians
have faced ongoing difficulty in fostering alternative payment and delivery models in
conjunction with agency partners. Without such models, specialists have no other option but to
engage in CMS’ Quality Payment Program (QPP) via the Merit-Based Incentive Payment System
(MIPS) track, as alternative payment models (APMs) – let alone Advanced APMs – are largely
unavailable or do not fairly measure the quality and costs of specialists compared to their
primary care colleagues.
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