American Society of Plastic Surgeons
For Consumers

FEDERAL | ASPS provides input on 2018 QPP Final Rule

In early January, ASPS submitted comments to Seema Verma, Administrator of the Centers for Medicare & Medicaid Services, outlining the Society's views on several decisions included in the 2018 Quality Payment Program (QPP) Final Rule. Additionally, ASPS joined with the Alliance of Specialty Medicine (ASM) as well as the Physician Clinical Registry Program (PCRP) to provide input on current and future proposals for the use of EMRs, scoring methodologies used in the QPP and the need for transparency with regards to the Qualified Clinical Data Registries review process.

The QPP is the new value-based reimbursement system used by CMS. The 2018 Final Rule implements new steps that the Agency is taking to incentivize high quality care over service volume.

Recognizing that the Rule included many positive changes, including raising the dollar and patient volumes required for participation in the QPP, each of the letters called on CMS to ensure predictable, multi-year approaches to how the Agency implements changes to the program. The PCRP as well as the ASPS letter gave examples of the difficulties societies have experienced during the QCDR review process, including disjointed communications, impractical timelines and the lack of clinical rationale for rejecting measures. The ASM letter included a call for CMS to revise its definition of small practices to ensure the Agency as well as providers accurately identify only those clinicians who are eligible for participation in the program.

ASPS routinely participates in CMS "open door" forums, and other QPP educational events the Agency provides. As future proposals about the program are announced, ASPS will continue to advocate for policies that are friendly to specialty providers.