August 22, 2017

ACR Responds to CMS’ QPP Proposed Rule to Ease Transition to MIPS and APMs

On Monday, August 21, the ACR submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the Medicare Program; CY 2018 Updates to the Quality Payment Program (QPP) proposed rule and addressed the proposed changes to year 2 of the Quality Payment Program (QPP).

Overall, CMS included proposals to further ease the transition to the QPP, especially to small and rural practices. The ACR provided specific comments and recommendations as they relate to changes to the QPP’s Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (AAPMs), such as small practice eligibility determination, small practice bonus, virtual groups, advancing care information significant hardship exception, AUC as a high weighted improvement activity, and facility-based measurement to name a few. The ACR also addressed the Advance APM requirements and the Physician-Focused Technical Advisory Committee (PTAC), which evaluates and recommends alternative payment models to the Secretary of HHS.

The comment letter addressed the following topics:

  • Small Practice Eligibility Determination
  • Rural Area and Health Professional Shortage Area (HPSA) Practices
  • Small Practice Bonus
  • Merit-Based Incentive Payment System (MIPS)
    • Identifying MIPS Eligible Clinicians (EC)
    • Low-volume threshold
    • Patient-facing Code List
    • Non patient-facing
    • Exclusions- Low-Volume Threshold
    • Eligibility of Clinicians Providing Services at Independent Diagnostic Testing Facilities (IDTFs)
    • Virtual Groups
    • Facility-based measurement
    • Performance period
    • MIPS: Quality Performance Category
    • Multiple Submission Mechanisms
    • MIPS: Advancing Care Information (ACI) Performance Category
    • MIPS: Cost Performance Category
    • MIPS: Improvement Activity (IA) Performance Category
    • Scoring Methodology
    • Scoring Improvement
    • MIPS: Third Party Data Submission
    • QCDR self-nomination process
  • Advanced Alternative Payment Models (AAPMs)
  • APM Criteria: Financial Rise
  • All-Payer Combination Option
  • Physician-Focused Payment Models (PFPMs)
  • Relationship Between PFPMs and Advanced APMs
  • PFPM Criteria  

Read the CY 2018 QPP proposed rule proposed rule comment letter.

For questions on the CY 2018 QPP proposed rule or the ACR comments on the rule, please contact Pam Kassing at, Judy Burleson at or Laura Pattie at