Society Joins Others in Sharing Concerns About MIPS With CMS

February 6, 2020
Policy Snapshot

This week, the Society joined the American Medical Association and others in writing to the Centers for Medicare & Medicaid Services (CMS) regarding the Merit-based Incentive Payment System (MIPS) quality measure selections and removal policy as finalized in the 2020 Physician Fee Schedule/Quality Payment Programs (QPP) final rule. The letter noted that the groups still have concerns with policies CMS has finalized and are particularly concerned with the direction of the Meaningful Measures Initiative due to the number of measures CMS removed from the 2020 MIPS programs. The groups also noted concerns regarding new measure removal factors and the current approach to measure harmonization.

The groups asked that CMS delay removal of measures in 2020 and institute a gradual timeline for removing measures as finalized in 2018. “CMS must also be more consistent with its rationales for removing measures. In many instances, the feedback provided in the proposed rule cited one reason, but CMS stated something different in the final rule. CMS could also easily address many of the reasons it provides for removing measures through changes to its program policies and/or methodologies,” the letter stated.

The groups also noted an increasing concern with CMS’ process for approving Quality Clinical Data Registry (QCDR) measures: “We understand CMS’ desire that all QCDR measures demonstrate reliability and validity, but the new measure testing requirement will be difficult for QCDRs to adhere to, particularly as it relates to the short and infeasible timeline. There are legal delays, and it can take several months to execute a testing contract with a testing vendor. There are also a limited number of testing vendors and, due to the large number of measures now required to undergo testing, we are concerned testing vendors will be unable to support the increased demand.”

Read the entire letter here.