April 20, 2018
The Honorable Seema Verma
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
Dear Administrator Verma:
On behalf of the undersigned organizations, we urge the Centers for Medicare & Medicaid Services (CMS) to reduce the 2018 Merit-based Incentive Payment System (MIPS) quality measure reporting period from a calendar year to a minimum of 90 consecutive days due to the lack of timely and direct notification by CMS on whether a physician is considered MIPS eligible, as well as a severe delay by CMS in updating the Quality Payment Program (QPP) interactive website with 2018 information. It is our understanding that CMS does not plan to update the QPP website with 2018 information and measures until the summer, at the earliest. Furthermore, we request a reduced reporting period for future MIPS program years in order to reduce administrative burden and ensure physicians have sufficient time to report after receiving performance feedback from CMS.
While we recognize CMS posted eligibility information on the QPP website on April 6, 2018, we are concerned with physicians’ ability to satisfactorily participate in the MIPS program due to the late notification. Several policy changes in 2018 from 2017 complicate physicians’ ability to determine their MIPS eligibility status. For example, CMS expanded the 2018 low-volume threshold exemption. While the undersigned organizations strongly support the increased lowvolume threshold and believe it will assist small practices and physicians who treat a small number of Medicare patients, it may create changes in physicians’ eligibility status.
In addition, the recently enacted Bipartisan Budget Act of 2018 modified MACRA to exclude Medicare Part B drug costs from MIPS payment adjustments and from the low-volume threshold determination of MIPS eligibility. As a result, physicians cannot rely on historic estimates from CMS and had to wait on notifications from CMS to determine whether they are excluded under the expanded low-volume threshold.
April 20, 2018