On Aug. 21, ACC submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed 2018 Medicare Quality Payment Program (QPP) rule, as published in the Federal Register on June 30. The proposed rule addresses participation requirements for 2018 and future years under the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (Advanced APM) pathways created by the Medicare Access and CHIP Reauthorization Act. Under the proposal, CMS will continue to treat the 2018 performance year as another transition year of QPP and maintain program flexibility.

The comments provide recommendations that "balance the goal of moving clinicians forward in a value-based payment system, while providing a stable environment in which this practice transformation can occur."

For the MIPS pathway, ACC comments specifically address the support of virtual group reporting with consideration for necessary assistance for some practices to implement this new option, continued flexibility for small practices and low-volume clinicians and groups, the support of streamlined scoring for MIPS APM participants, support for reporting MIPS categories using multiple submission mechanisms, discussion of proposed changes to MIPS scoring, including a transition to a mean or median approach in Year 3 of QPP, and concerns with the current qualified clinical data registry self-nomination process, among other topics.

In regard to the Advanced APM pathway, the College expresses cautious support of the All-Payer Combination Option concept overall, with opposition to the proposal to measure risk at the individual eligible clinician level, support for maintaining the current nominal risk standard for the 2019 and 2020 performance years, along with additional flexibility for small and rural practices, and support of expanding the scope of Physician-Focused Payment Models to consider Medicaid and Children's Health Insurance Plan arrangements.

As performance data and newly modeled data become available, ACC requests that CMS share it with practicing clinicians, medical societies and other stakeholders to continue fostering productive discussion and collaboration on meaningful improvements to the QPP.

"The ACC looks forward to ongoing discussion and collaboration with CMS to develop policies that support the ability for clinicians to focus on the delivery of high-quality patient care under an evolving value-based payment environment. The College is encouraged to see that in addition to the Year 2 QPP proposals presented in this rule, CMS is already thinking ahead to how these policies may impact Year 3 participation," writes ACC President Mary Norine Walsh, MD, FACC.

The College will continue to advocate for a clear, streamlined program that appropriately recognizes clinicians for their efforts to provide Medicare beneficiaries with high-quality care whenever possible. ACC Advocacy staff are diligently monitoring new developments to these QPP participation requirements. Get the latest information through ACC's MACRA Information Hub, the Advocate newsletter and @Cardiology on Twitter. Read the full comment letter here.

Keywords: Medicaid, Centers for Medicare and Medicaid Services, U.S., Medicare, Health Expenditures, Patient Care, Registries

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