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    DEPARTMENT OF HEALTH AND HUMAN SERVICES                                                                         
    Centers for Medicare & Medicaid Services
    7500 Security Boulevard, Mail Stop S3-02-01
    Baltimore, Maryland 21244-1850

    February 13, 2018

    Mr. Anders M. Gilberg
    1717 Pennsylvania Avenue NW #600
    Washington, DC 20006

    Dear Mr. Gilberg:

    Thank you for contacting the Centers for Medicare & Medicaid Services (CMS) regarding the 12 months of quality data and the eligibility requirements for Performance Year 2 (2018) of the Quality Payment Program (QPP), specifically as it relates to the Merit-based Incentive Payment System (MIPS).

    As you know, the QPP 2018 Final Rule requires 12-months of data for the Quality and Cost performance categories in Year 2. For the 2017 Transition Year, a 12-month reporting period for Quality was also encouraged, but given the participation flexibility through Pick Your Pace, clinicians had the option to report as little as one day of quality data to satisfy the minimum reporting requirements.

    Requiring 12-months of quality data reporting moves us towards a more robust program in Year 3 (2019). We would also like to emphasize that in Year 2 (2018), the program is structured so that a clinician can still perform well in MIPS overall, if they put forth efforts in quality and the other performance categories and/or receive bonus points.


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