On Dec. 19, the ACC submitted formal comments in response to a final rule released in November regarding the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) incentive under the Physician Fee Schedule, and criteria for Physician-Focused Payment Models. 

In the comment letter to Acting Centers for Medicare and Medicaid Services (CMS) Administrator Andrew M. Slavitt, the College notes its support for the “depth of changes” included in the final rule as a result of public comments, including those from the ACC. However, the letter also cautions that CMS “still has a heavy lift ahead in ensuring that the [Quality Payment Program (QPP)] is implemented in a way that truly supports improved patient outcomes without distracting clinicians from their priority of treating patients.” As such, the letter highlights several key areas where further improvements are needed in order to achieve this goal, as well as encourages continued clarification and education on how best to implement 2017 QPP policies into practice.

In particular, the comments call for the QPP transition period to be extended beyond the 2017 performance/2019 payment year in order for clinicians and groups to understand and process the feedback on their performance. Additionally, the College also recommends that CMS preserve the “Pick Your Pace” reporting options for 2018 and continue to implement additional solutions that support clinicians and groups in the transition to the QPP. The letter also requests that CMS carefully test the concept of virtual groups as a reporting option for helping small practices succeed under MIPS.

“While CMS made many improvements to the MIPS policies in the final rule, CMS should continue to develop this pathway so that it truly is one seamless reporting program rather than the separate, disjointed legacy programs of Physician Quality Reporting System, the Electronic Health Record Incentive, and the Value-Based Payment Modifier,” the letter goes on to state. It also recommends that CMS continue to update the list of Advanced APMs and refine policies to make this QPP participation pathway available to more specialists and clinicians.

Moving forward, the ACC notes that “the continued refinement of the QPP will require ongoing dialogue between CMS and the clinicians, patients, vendors and other stakeholders affected by this program,” particularly as unforeseen issues arise. Read the complete comment letter. Learn more about MACRA and QPP implementation in the ACC’s online MACRA hub.