RE: CY 2018 Updates to the Quality Payment Program
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.
Today, the undersigned organizations of the Alliance write to express appreciation, share ongoing
concerns, and provide additional input as you implement 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 Implementation of the Quality Payment
Program
The Alliance appreciates the many improvements and flexibilities CMS has provided to small practices,
several of which will benefit specialty physician practices. We thank CMS for finalizing the small practice
bonus and increasing the complex patient bonus. We also thank CMS for eliminating the burden of
reporting data as part of the Advancing Care Improvement (ACI) performance category for small
practices that may not have the resources to adopt certified electronic health record technology
(CEHRT). We appreciate that CMS maintained its policy that reduces the burden of reporting through
the Improvement Activities (IA) performance category by doubling the points available for high and
medium weighted activities. Small, specialty-focused practices are poised to reap many other benefits
and flexibilities as a result of the finalized policies dedicated to small practices.
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