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AAMC Comments on CMS Quality Measure Development Plan

March 4, 2016—The AAMC March 1 submitted comments  on the Centers for Medicare and Medicaid Services (CMS’s) quality measure development plan supporting the transition to the new physician performance programs under the Medicare Access CHIP Reauthorization Act (MACRA, P.L. 114-10).

Beginning in 2019, physicians will have the option to have their performance assessed under a newly consolidated pay-for-performance program, Merit-based Incentive Payment System (MIPS), or receive incentives for participation in Alternative Payment Models (APMs).

The AAMC’s comments outline concerns with the state of physician quality measurement, and recommend that CMS address a number of key issues moving forward under MACRA. These issues include appropriate risk-adjustment for outcome measures, a holistic and continuous review of measures, a transparent review process, allowing physicians’ sufficient time to prepare for implementation of new measures, and reducing administrative burden.

Regarding risk adjustment concerns, the AAMC notes that socio-demographic status, patient severity, rates of patient compliance with treatment, patient engagement, patient preferences for treatment approaches, and sites of care can all drive differences in outcomes. The association requests that CMS support additional research efforts to examine and account for these issues under the MIPS and APMs.

The AAMC also raises concerns with electronic health measure burden, the validity and reliability of certain quality measures, and the inclusion of certain population health measures on individual physicians. CMS is expected to publish additional regulations governing MIPS and APMs in spring 2016.


Scott Wetzel, M.P.P.
Lead, Quality Reporting
Telephone: 202-828-0495

Gayle Lee
Director, Physician Payment & Quality
Telephone: 202-741-6429


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806