Society Letters

Letter to CMS on MIPS Value Pathways

April 10, 2020

To: CMS Administrator Seema Verma

"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 reduce burden and focus reporting around an episode of care and patient outcomes. The high-level framework outlined by CMS in last year’s Quality Payment Program (QPP) rule was an important step in the right direction, but we believe that the MVP pathway needs to be structured appropriately to effectively improve the relevance of MIPS to clinical practice and reduce unnecessary paperwork burdens. Specifically, we strongly recommend that CMS ensure that MVP participation is voluntary, create a transition period, focus on measures that are meaningful to physicians, promote the use of new and innovative health information technology, dramatically reduce reporting burden by streamlining reporting, and ensure there are appropriate incentives for physicians to report on new measures and as a sub-group."

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