Dear Acting Administrator Richter:
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
establish an option that moves the program away from a very individualistic method of reporting to a
more holistic, episodic or condition-focused approach with a clear end goal of improving patient
outcomes. We greatly appreciate the ongoing dialogue between CMS and our organizations about
opportunities to improve patient care through MVPs. CMS should not feel pressured to rush into
launching MVP as it is more important to ensure that each MVP is well-designed with agreement
from the relevant specialties. Due to the COVID-19 public health emergency, practices have had the
option to opt out of MIPS since 2019. We offer the below recommendations to ensure the MVP is
successfully implemented and we strongly urge CMS to address these issues in the 2022 Quality
Payment Program proposed rule.
Read full letter here
