April 10, 2020
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building, Room 445-G
200 Independence Avenue, SW
Washington, DC 20201
Dear Administrator Verma:
The undersigned physician organizations agree with the Centers for Medicare & Medicaid Services’
(CMS’) aims in the Merit-based Incentive Payment System (MIPS) Value Pathway (MVP) to reduce
burden and focus reporting around an episode of care and patient outcomes. The high-level framework
outlined by CMS in last year’s Quality Payment Program (QPP) rule was an important step in the right
direction, but we believe that the MVP pathway needs to be structured appropriately to effectively
improve the relevance of MIPS to clinical practice and reduce unnecessary paperwork burdens.
Specifically, we strongly recommend that CMS ensure that MVP participation is voluntary, create
a transition period, focus on measures that are meaningful to physicians, promote the use of new
and innovative health information technology, dramatically reduce reporting burden by
streamlining reporting, and ensure there are appropriate incentives for physicians to report on new
measures and as a sub-group.
Read full letter here
