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Association Comments on Finalized Quality Payment Program Updates

America’s Essential Hospitals urged the Centers for Medicare & Medicaid Services (CMS) to account for social risk factors and patient complexity in performance management through the Quality Payment Program (QPP).

This recommendation came in a Dec. 22 letter commenting on the final rule with comment period for calendar year 2018 updates to the QPP, the physician payment system required by the Medicare Access and CHIP Reauthorization Act of 2015. CMS finalized provisions that build on transition year policies and introduced new policies allowing clinicians to choose how to participate in either the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (APMs).

In its comments, America’s Essential Hospitals recommended that CMS:

  • implement a facility-based measurement option for the MIPS 2020 payment year and adopt a flexible eligibility definition;
  • risk adjust measures in the MIPS when warranted and streamline efforts to focus on the highest-priority measures;
  • continue to weigh the MIPS cost category at zero percent;
  • move forward with its policy to incorporate bonus points for MIPS-eligible clinicians who care for complex patients, set a higher cap for such points, and consider social risk factors in addition to Hierarchical Condition Category and dual-eligible status when determining patient complexity;
  • continue to engage stakeholders in development of Other Payer Advanced APMs and develop a simple attestation process related to this QPP pathway; and
  • finalize its extreme and uncontrollable circumstances policies for the 2017 and 2018 MIPS performance years and apply such policies uniformly across the QPP.

Contact Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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