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The Center for Medicare Advocacy submitted comments this week to the Centers for Medicare & Medicaid Services (CMS) concerning the proposed rule on the Medicare Program Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule (CMS–5571–P), two elements proposed in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

The Center’s overarching comments for both MIPS and Advanced APMs touched on risk adjustment for socio-economic status and on the importance of outcome measures that meet individually assessed needs. Regarding MIPS, the Center commented that the proposal gives too much latitude to clinicians to choose measures that they can meet without having to demonstrate that they assess the needs of the individual patient. Overall the Center hopes that the MIPS category can become more meaningful, more evidence-based, and better positioned to promote better patient health outcomes.

Regarding Advanced APMs, given the great flexibility afforded to existing entities that qualify for Advanced APM status under the proposed rule, the Center recommends that CMS offer patient advocacy groups greater input into the design of Advanced APM measures, payments, and informational materials sent to beneficiaries. We also encourage CMS to require entities applying to become Advanced APMs in the future to use clinical care models that results in improved delivery of care, such as the Medical Home Models.

The Center’s comments are available at

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