SUBJECT: CY 2020 Revisions to Payment Policies under the Physician Fee Schedule
Dear Ms. Verma,
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), we appreciate the opportunity to provide comments on the quality-related
provisions of the proposed 2020 Medicare physician fee schedule. We will address issues related to the
coding, reimbursement and other payment issues in a separate letter.
Merit-Based Incentive Payment System (MIPS)
MIPS Value Pathways (MVPs) framework. In this rule, the Centers for Medicare & Medicaid Services
(CMS) propose to apply a new MIPS Value Pathways (MVPs) framework to future proposals beginning
with the 2021 MIPS performance year. MVPs are intended to create a more cohesive and meaningful
participation experience for clinicians by moving toward an aligned set of measures that are more
relevant to a clinician’s scope of practice, while further reducing reporting burden and easing the
transition to APMs through enhanced and timely performance feedback. Under the framework, a
clinician or group would participate in one MVP associated with their specialty or with a condition,
reporting on the same measures and activities as other clinicians and groups in that MVP. Measures
and activities would cover all four MIPS performance categories and could include fewer total measures
than currently required under MIPS.
Read full letter here
