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    April 13, 2021 

    Elizabeth Richter
    Acting Administrator
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building, Room 445–G
    200 Independence Avenue, SW
    Washington, DC 20201

    Dear Acting Administrator Richter:

    On behalf of the undersigned organizations, thank you for providing much-needed relief for physicians in the Merit-based Incentive Payment System (MIPS) by instating an automatic and flexible Extreme and Uncontrollable Circumstances Hardship Exemption policy for the 2020 MIPS performance year due to the COVID-19 Public Health Emergency (PHE). We write today to urge additional action to provide greater transparency in MIPS. Specifically, we ask that CMS immediately release the 2018, 2019, and 2020 MIPS cost measures benchmarks and further make cost measure benchmarks and patient attribution information available on a rolling, close to real-time basis during the 2021 performance year and future performance periods thereafter. We also continue to remain concerned with the lack of timeliness on the release and consistency with the quality measure benchmarks.

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