SUBJECT: MIPS Value Pathways Program
Dear Dr. Schreiber:
The undersigned organizations are reaching out regarding the Centers for Medicare & Medicaid
Services (CMS) draft Merit-based Incentive Payment System (MIPS) Value Pathways candidate
on Improving Outcomes for Degenerative Spinal Disease. Together, our organizations1
represent the physicians who provide surgical and therapeutic procedures to patients with
degenerative spinal disease.
We appreciate CMS seeking our feedback on this draft MIPS Value Pathways (MVP). As
highlighted in previous communications, measuring the value of spine disease is complex given
the diversity of procedures used to treat a significantly heterogeneous patient population.
Given the complexity of this population and the current limitations of MIPS to incentivize
care coordination across episodes of care, we do not believe that a Degenerative Spine
Disease MVP is feasible at this time. We therefore strongly recommend that CMS
suspend this topic for the first wave of MVPs for 2022. Instead, we urge the agency to
continue to work with our specialties to find a more feasible solution for measuring
quality and costs related to this population.
Read full letter here
