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CMS Comment Period for Quality Payment Program Ends Dec. 19

Stakeholders can comment on both parts of the Quality Payment Program, including MIPS and advanced APMs, CMS says.

By Sara Heath

- Time is running out for healthcare professionals, lawmakers, patients, and caregivers to submit public comment on the Quality Payment Program.


In a public statement, CMS announced that it will continue to accept public comments until December 19 in an effort to create a user-centric program.

The agency stated that it seeks comments on both arms of the Quality Payment Program — the Merit-based Incentive Payment System (MIPS) and advanced alternative payment models (advanced APMs).

For MIPS, CMS specifically seeks comments about virtual groups, planned for implementation in 2018. Stakeholders should comment on the following:

  • establishing minimum standards for members of virtual groups,
  • how virtual groups could use their data for analytics,
  • whether the initial implementation of virtual groups should be in the form of a pilot study,
  • requirements that could facilitate use of virtual groups to enhance health outcomes and goals such as coordination of care, and
  • use of a group identifier for virtual groups.

Additionally, CMS seeks comment on MIPS scoring, such as how to score non-outcomes measures, alternative approaches to establishing measures benchmarks, and handling topped out measures.

The agency also seeks comment on how to score groups with non-eligible clinicians, the low-volume threshold, the quality performance category, the advancing care information performance category, and how to define non-patient-facing measures.

With regard to advanced APMs, CMS is looking for comments on the design of the Other Payer Advanced APMs model, which would engage eligible clinicians participating in a non-Medicare sponsored advanced APM.

Additionally, CMS seeks comments on the All-Payer Combination, which would determine whether Medicare APMs should be categorized as Other Advanced APMs prior to a QP Performance Period.

Stakeholders may submit their comments via email or regular mail until 5 p.m. on December 19.



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