On June 27, 2016, Astellas submitted to the Centers for Medicare and Medicaid Services (CMS) comments on the agency’s proposed rule on the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models.
Our comments outline a number of concerns with the proposal and urge the agency to reconsider the proposed rule, including:
- The proposed rule needs refinements to focus better on specialty physicians
- CMS should strongly encourage NQF endorsement of MIPS and APM quality measures
- CMS should emphasize patient-reported outcome measures in quality evaluations
- CMS should proceed cautiously before incorporating Part D drug costs into the MIPS resource use performance category
- CMS should encourage collaborative arrangements between manufacturers and providers
Please find our full comments here.