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Premier Submits Comments on Proposed CY 2020 MIPS and Advanced APM Policies

Premier submitted comments on CMS' proposed policies on MIPS and Advanced APMs in the CY 2020 proposed physician fee schedule. Highlights include:

  • The proposed rule includes an inquiry of aligning the accountable care organization (ACO) reporting with the Merit-based Incentive Payment System (MIPS). Premier opposes this concept because ACOs should focus on measures related to total cost of care rather than physician specific measures in MIPS, the ACO program recently underwent a significant overhaul with the Pathways to Success, and CMS is considering making additional changes to MIPS.
  • Premier supports CMS’ efforts to provide more flexibility in how Other Payer Arrangements meet the Advanced Alternative Payment Model (APM) Criteria (i.e. using an average marginal risk rate) but we oppose efforts to restrict flexibility (i.e. limiting Other Payer Medical Homes to CMMI multi-payer models)
  • Premier conceptually supports CMS’ proposed redesign of MIPS, the MIPS Value Pathways (MVP); however, additional detail is needed for stakeholders to effectively weigh in. We encourage CMS to work with stakeholders, particularly specialty societies who own Qualified Clinical Data Registries, to further define MVP.
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