SUBJECT: CY 2018 Updates to the Quality Payment Program (CMS-5522-FC)
Dear Administrator Verma:
On behalf of the American Association of Neurological Surgeons (AANS) and the Congress of
Neurological Surgeons (CNS), representing more than 4,000 neurosurgeons in the United States, we
appreciate the opportunity to provide additional feedback on the 2018 Quality Payment Program (QPP)
final rule with comment period. As we stated previously, the AANS and CNS recognize that
implementing the Medicare Access and CHIP Reauthorization Act (MACRA) is a challenging task. As
such, we appreciate that in the final rule, CMS commits to the following critical strategic objectives:
- Enhancing clinician experience through flexible and transparent program design and interactions with easy-to-use program tools;
- Promoting program understanding and maximizing participation through customized communication, education, outreach and support that meet the needs of the diversity of physician practices and patients, especially the unique needs of small practices;
- Improving data and information sharing on program performance to provide accurate, timely, and actionable feedback to clinicians and other stakeholders;
- Delivering information technology system capabilities that meet the needs of users for data submission, reporting, and improvement and are seamless, efficient and valuable on the front and back-end; and
- Ensuring operation excellence in program implementation and ongoing development.
Still, the AANS and CNS remain deeply concerned by CMS’ efforts to advance Merit-based Incentive
Payment System (MIPS) policies in the absence of making more concrete progress on each of these
foundational strategic objectives. Below, we discuss some of our ongoing concerns with existing and
newly finalized MIPS policies for 2018, and why they fail to advance the above objectives.
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Read full letter here
