Comment Letter | Physician Payment and Reimbursement

HFMA Comments on the CY18 Updates to the Quality Payment Program Proposed Rule

Comment Letter | Physician Payment and Reimbursement

HFMA Comments on the CY18 Updates to the Quality Payment Program Proposed Rule

HFMA submitted comments to CMS on the CY 2018 Quality Payment Program proposed rule.

HFMA would like to commend CMS for its thorough analysis and discussion of the myriad Medicare physician reimbursement decisions addressed in the Quality Payment Program (QPP) Proposed Rule. As an organization, HFMA fully supports the transition to outcomes-based payment. Our members see this as crucial to efforts to improve the value of care delivered. To help our members successfully lead their organizations through this complex transition, we continue to publish the best practices of leading organizations through our Value Project research.
HFMA’s members have specific concerns and questions regarding the proposals related to the following:

  • Merit-Based Incentive Program (MIPS)
    • Increased Flexibility
    • Patient Complexity Adjustment
    • Definition of a Group Practice - Split Reporting TINs (Taxpayer Identification Numbers)
    • Improvement Bonus Methodology
  • Advanced Alternative Payment Model (AAPM) Incentive
    • Availability of AAPM Models
    • “All-Payer Option” Administrative Burden
  • Opportunities for Administrative Simplification
    • Necessary Changes to the Fraud and Abuse Regulations
    • Aligning Meaningful Use Across Programs and Care Delivery Settings
    • Improving Quality and Cost Measures
    • Supporting Physician Practices

Download the comment letter 


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