January 31, 2020
The Honorable Seema Verma
Administrator
Centers for Medicare & Medicaid Services U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, DC 20201
Re: Quality Payment Program
Dear Administrator Verma,
The undersigned organizations are writing regarding CMS’ MIPS quality measure selection and removal policy as finalized in the 2020 Physician Fee Schedule/Quality Payment Program (QPP) Final Rule. We appreciate the ongoing dialogue we have had with CMS to improve the Merit-based Incentive Payment (MIPS) program over the years but continue to have concerns with policies CMS has finalized and, welcome the opportunity to continue the conversation and work with CMS on solutions. While we generally support a more refined set of quality measures, we are particularly concerned with the direction of the Meaningful Measures Initiative due to the number of measures CMS removed from the 2020 MIPS program. We also have concerns regarding the new measure removal factor and the current approach to measure harmonization.