Dear Acting Administrator Richter:
On behalf of the undersigned organizations, thank you for providing much-needed relief for
physicians in the Merit-based Incentive Payment System (MIPS) by instating an automatic and
flexible Extreme and Uncontrollable Circumstances Hardship Exemption policy for the 2020 MIPS
performance year due to the COVID-19 Public Health Emergency (PHE). We write today to urge
additional action to provide greater transparency in MIPS. Specifically, we ask that CMS
immediately release the 2018, 2019, and 2020 MIPS cost measures benchmarks and further
make cost measure benchmarks and patient attribution information available on a rolling,
close to real-time basis during the 2021 performance year and future performance periods
thereafter. We also continue to remain concerned with the lack of timeliness on the release and
consistency with the quality measure benchmarks.
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