American Society of Plastic Surgeons
For Consumers

FEDERAL | ASPS comments on CMS proposed rule for 2018 Quality Payment Program

This month, ASPS submitted comments in response to the Centers for Medicare & Medicaid Services (CMS) proposed rule for the 2018 Quality Payment Program (QPP). In the letter, ASPS stated that the Agency's proposal to raise scoring and participation requirements in year two may be premature. The Society reminded CMS that the "Pick Your Pace" program is less than a year old and has not garnered adequate analysis on results, data collection or provider participation. ASPS also highlighted that small practices have had limited exposure to previous quality program and may not have the institutional knowledge to successfully participate in the proposed enhancements for CY2018 without additional latitude in how scoring is calculated.

ASPS also signed on to comment letters by the Alliance of Specialty Medicine and the Physician Clinical Registry Coalition, both of which ASPS is a member. Letters by these coalitions stressed the need for an organized, transparent and consistent measure review process and requested that current and future reporting options be simplified. The Alliance letter also encouraged the Agency to streamline the Merit-based Incentive Payment System (MIPS), integrating its four performance categories into a more cohesive program and noted the need for additional training, educational tools and technical assistance for specialty physicians.

In the coming months, the Agency will review all comments received and possibly adjust the proposed requirements for the 2018 performance year based on stakeholder feedback. CMS has recently appeared more cognizant of the need to reduce administrative burdens inherent in their payment program, which will hopefully be reflected in revisions made by the Agency to the proposal. Changes for year 2 of the QPP will be made public through the Agency's Final Rule, which is historically released in mid-November each year.