ACC Comments on Programmatic Changes in Proposed 2020 Medicare PFS

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The ACC has submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) to address programmatic changes in the proposed 2020 Medicare Physician Fee Schedule, with a particular focus on opportunities for bundled payments, Merit-Based Incentive Payment System (MIPS) Value Pathways, changes to the Quality Payment Program (QPP), Medicare Shared Savings Program, electronic health records and health data, and more. A separate letter addressing pricing aspects of the proposed rule was submitted earlier this month.

The letter includes five key requests regarding ongoing implementation of the Quality Payment Program: 1) Continue efforts to prevent the QPP from being an administrative burden on clinicians; 2) Finalize programs that adequately balance flexibility with quality patient care; 3) Provide clinicians with meaningful measures appropriate to the patient population of interest; 4) Provide enough time for the development of novel paths and frameworks to meet QPP performance goals in the following year and years to come; and 5) Continue to eliminate barriers to Alternative Payment Model (APM) participation.

The ACC letter also provides detailed comments on several MIPS proposals, including one to align the electronic clinical quality measures (eCQMs) available for Medicaid eligible providers (EPs) in 2020 with those available for MIPS eligible clinicians for the CY 2020 performance period. Another proposal would replace the Medicare Shared Savings Program (MSSP) quality performance score with the MIPS quality score for accountable care organizations (ACOs) in MSSP tracks that do not qualify as Advanced APMs. Topics related to data sharing, EHRs and interoperability are also addressed in the letter, with the need for stakeholder collaboration, education and transparency serving as fundamental aspects of the College's recommendations.

CMS is expected to release the final physician fee schedule rule by Nov. 2. ACC leaders and Advocacy staff will continue to collaborate with CMS, partner cardiovascular societies and the broader medical community as the rulemaking process moves forward.

Keywords: ACC Advocacy, Medicaid, Accountable Care Organizations, Centers for Medicare and Medicaid Services, U.S., Medicare, Fee Schedules, Health Expenditures, Electronic Health Records, Patient Care

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