Input on CMS Proposed MIPS and APM Incentives Rulemaking

The HCTTF supports the policies of MACRA and moving Medicare payment for physician services to a value-based formula that focuses on quality, resource use, clinical practice improvement, and meaningful use of certified EHR technology under the Medicare Incentive Payment System. As a major proponent of value-based care furnished through alternate payment models, the HCTTF also supports the opportunity for qualifying physicians to benefit from participating in Advanced APMs or MIPS APMs.
Our comments primarily focus on the proposed policies addressing Advanced APMs and MIPS APMs. While MIPS represents an important policy change in the Medicare payment program, it runs the risk of hindering industry progress in coordinating care between physicians and other health care providers occurring today in existing APMs. The Medicare program is currently advancing many APMs, and understandably physicians play a critical role in all of them. We urge CMS to interpret “Advanced APMs” and “MIPS APMs” in ways that support the maturation of ongoing value-based payment models occurring in existing APMs. Conversely, we recommend avoiding promulgating policies that create significant distractions or misaligned incentives for participating physicians that challenge or harm the transformation efforts of existing APMs.

Read the letter for an in-depth review of the Task Force recommendations.


read the letter here


Letter submitted on June 27, 2016