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    May 4, 2021 

    The Honorable Xavier Becerra
    Secretary
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building
    200 Independence Ave, S.W.
    Washington, DC 20201

    Re: Request to Delay Mandatory Reporting of eCQMs and MIPS CQMs and Implement Changes to the Medicare Shared Savings Program Quality Overhaul

    Dear Secretary Becerra:

    The undersigned organizations write to express our increasing concerns with the recent changes to quality reporting for the Medicare Shared Savings Program (MSSP), which were finalized in the Final 2021 Medicare Physician Fee Schedule Rule (CMS-1734-P), as published in the Federal Register on December 28, 2020. Quality improvement is a cornerstone of the ACO model. In addition to reducing spending, ACOs must meet quality performance standards to be eligible to receive shared savings payments. ACOs continue to improve quality year over year, which improves patient care and helps to control costs. It is critical that policies to evaluate ACO quality are fair, appropriate and accurately reflect the work ACOs undertake to improve patient care.
     

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