Hospital Association of Pennsylvania > Advocacy > Federal Advocacy > MIPS and APM Incentives Comment Letter


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HAP Comment Letter to CMS about MIPS and APM Incentives Under the Physician Fee Schedule and Criteria for Physician-Focused Payment Models

June 27, 2016

Andy Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201

SUBJECT: CMS-5517-P Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models

Dear Mr. Slavitt:

On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to provide comments about the implementation of the Quality Payment Program (QPP), which includes the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Models (APM).

With nearly two-thirds of physicians being employed or under contract by hospitals and health systems in Pennsylvania, HAP member hospitals and health systems represent a key constituency of health care providers affected by changes related to the Medicare Access and CHIP Reauthorization Act of 2015.

HAP supports many of the flexibilities CMS has proposed for the MIPS and APMs, including reducing the number of quality measures in the MIPS and greater flexibility for providers to qualify as participating in an advanced APM.

HAP remains concerned about:

  • The continued viability for small provider practices
  • The lack of consideration for socioeconomic/demographic factors
  • The insufficient time allotted to implement necessary changes from the time the final rule is released to the start of measurement
  • The limited approach to defining alternative APMs

Thank you for your consideration of HAP’s comments. If you have any questions, contact me at (717) 561-5325, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.


Jeffrey W. Bechtel
Senior Vice President, Health Economics and Policy


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