Task Force Letter to CMS Regarding Medicare Access and CHIP Reauthorization Act of 2015 RFI

The Task Force supports policies that promote value-based care and applauds the efforts of CMS to enhance these endeavors. The MACRA provisions increase a provider’s ability to provide quality care and improve patient outcomes, as well as achieve cost efficiencies. However, care must be taken to define these models in a way that promotes (not hinders) achievement of the desired results. We strongly support the inclusion of incentive for provider participation in Alternative Payment Models (APMs) in MACRA, and see the Merit-Based Incentive Payment System (MIPS) as a pathway toward APM participation. As such, it is important that CMS propose regulations that create allowances and incentives for providers that desire to transition to an APM. Our comments build off this foundation and respond directly to the following RFI sections under the APM portion of the RFI (unless otherwise specified): (1) Eligible Provider Identifier (MIPS), (2) Virtual Groups (MIPS), (3) Patient Approach, (4) Nominal Financial Risk, (5) Medicaid Medical Home Models, (6) Eligible APM entity requirements, and (7) quality measures.


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Letter submitted on November 17, 2015