The Alliance of Specialty Medicine filed comments with CMS Administrator Seema Verma in response to the proposed Medicare Physician Fee Schedule for Calendar Year 2021 and the Quality Payment Program in Year 5.  In their nine page letter, the Alliance endorsed these key recommended actions: 

1. Work with Congress to eliminate the negative impact of the many changes in evaluation and management (E/M) payment and related policies; 

2. Establish policies that expand access to telehealth and virtual care services while addressing utilization and program integrity vulnerabilities; 

3. Create pathways that enable meaningful specialist participation in Medicare Shared Savings Programs; 

4. Extend the timeframe for updating certified electronic health record technology (CEHRT); 

5. Delay implementation of the MIPS Value Pathways (MVPs) and make key improvements to the program; 

6. Allow clinicians in MIPS APMs to continue to benefit from Cost and Improvement Activity category scoring efficiencies regardless of what Quality measures they report; 

7. Retain the current (Year 4) MIPS Quality and Cost performance category weights and performance thresholds, in light of COVID-19 disruptions; 

8. Make COVID-19-related hardship exemptions available during CY 2021 for MIPS eligible clinicians; and 

9. Adopt a streamlined approach to APM incentive payments that permits payment to individual QPs. 

Click Here to Access the Letter.