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March 5, 2021: MGMA and other leading health advocacy groups urge CMS to improve MIPS MVPs

Advocacy Letter - March 8, 2021

March 05, 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:

The undersigned physician organizations agree with the Centers for Medicare & Medicaid Services’ (CMS) aims in the Merit-based Incentive Payment System (MIPS) Value Pathway (MVP) to establish an option that moves the program away from a very individualistic method of reporting to a more holistic, episodic or condition-focused approach with a clear end goal of improving patient outcomes. We greatly appreciate the ongoing dialogue between CMS and our organizations about opportunities to improve patient care through MVPs. CMS should not feel pressured to rush into launching MVP as it is more important to ensure that each MVP is well-designed with agreement from the relevant specialties. Due to the COVID-19 public health emergency, practices have had the option to opt out of MIPS since 2019. We offer the below recommendations to ensure the MVP is successfully implemented and we strongly urge CMS to address these issues in the 2022 Quality Payment Program proposed rule.

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