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    September 23, 2020 

    Ms. Seema Verma Administrator
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building
    200 Independence Avenue, S.W.
    Washington, DC 20201

    Re: (CMS-1734-P) Medicare Program: CY 2021 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements

    Dear Administrator Verma,

    The undersigned organizations write to provide comments on the proposed quality revisions for Accountable Care Organizations (ACOs) included in the proposed 2021 Medicare Physician Fee Schedule rule. CMS proposes sweeping changes to how ACO quality is assessed, how quality data is reported and how ACOs are evaluated on quality for both the Medicare Shared Savings Program (MSSP) and Merit-Based Incentive Payment System (MIPS). We appreciate that the Centers for Medicare and Medicaid Services (CMS) has considered how to reduce the required number of measures, provide flexibility in how measures are submitted and mitigate potential reductions in 2020 performance by using the higher of 2019 or 2020 scores. However, the timing of these changes is very concerning as ACOs continue to deal with the uncertainty that the COVID-19 Public Health Emergency (PHE) is bringing to the health care industry. Additionally, the expected delayed release of the final rule further reduces the amount of time ACOs and other Alternative Payment Models (APMs) will have to implement such changes.

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