In an August 21 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to the proposed annual update to the Quality Payment Program (QPP).

Proposed updates for calendar year 2018 — year two of the QPP — include changes to existing requirements, as well as clinician flexibility on how to participate in the merit-based incentive payment system’s (MIPS’) default track or as part of an Advanced Alternative Payment Model (APM).

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

  • adopt a facility-based measurement scoring option for the MIPS;
  • risk adjust measures before inclusion in the MIPS;
  • incorporate bonus points for MIPS-eligible clinicians who care for complex patients; and
  • continue to engage stakeholders in development of future models to encourage participation by essential hospitals in Advanced APMs.

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