January 31, 2019
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201
Re: Quality Payment Program
Dear Administrator Verma,
The undersigned organizations are writing regarding CMS’ MIPS quality measure selection and removal
policy as finalized in the 2020 Physician Fee Schedule/Quality Payment Program (QPP) Final Rule. We
appreciate the ongoing dialogue we have had with CMS to improve the Merit-based Incentive Payment
(MIPS) program over the years but continue to have concerns with policies CMS has finalized and,
welcome the opportunity to continue the conversation and work with CMS on solutions. While we
generally support a more refined set of quality measures, we are particularly concerned with the direction
of the Meaningful Measures Initiative due to the number of measures CMS removed from the 2020 MIPS
program. We also have concerns regarding the new measure removal factor and the current approach to
measure harmonization.
In addition, we oppose the new testing requirement placed on qualified clinical data registry measures
(QCDR) in light of the short timeline provided to comply. Key to the success of MIPS and the transition
to MIPS Value Pathways (MVPs) and reducing administrative burden is having a portfolio of appropriate
quality measures that are applicable to each physician specialty to help improve the care of their patients.
A specialty specific approach to measurement allows patients to make better assessments about care and
helps create greater value and higher quality care.
Since the inception of MIPS, CMS has stated that it wants to reduce burden, encourage the use of
reporting through electronic means, promote the use of qualified clinical data registries (QCDRs) and
increase reporting on outcome and patient reported outcome measures. However, physicians and
organizations are disincentivized to report through a QCDR or devote resources to measure development
or QCDR development when there is no stability in quality reporting policies. The constant churn also
increases physician burden and frustration with the MIPS program. For instance, it is difficult to justify
spending millions of dollars on developing new measures when CMS finalized a policy to remove
measures with low reporting rates after only two years in the program. The policy fails to acknowledge
the time needed to adopt new guidelines and standards of care into practice. In addition, it takes time for
sufficient data to be collected for benchmarking and tracking progress over time and physicians incur
additional implementation costs. These challenges, as well as CMS’ MIPS scoring policies, contribute to
physician hesitation to adopt new quality measures. We believe that the field of performance
measurement and our shared goal to improve the quality of care for patients are negatively impacted by
these policy decisions
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