ASA Submits Comments on 2018 Quality Payment Program Proposed Rule

On August 21, 2017, the American Society of Anesthesiologists® (ASA) submitted to the Centers for Medicare & Medicaid Services (CMS) comprehensive comments in response to the 2018 Quality Payment Program (QPP) Proposed Rule. In this 28-page letter, ASA focused on ensuring physician anesthesiologists have ample opportunities to meaningfully participate and succeed in either the Merit-based Incentive Payments System (MIPS) or Advanced Alternative Payment Models (APMs) pathways under the QPP.

Although the QPP is still in its regulatory infancy, the burden on CMS to further roll out this complex program in an inclusive and fair way, minimizing whenever possible the associated administrative burdens, is a significant challenge.

Among the dozens of recommendations and comments aimed at improving the program, ASA:

• Supported the concept of voluntary use of facility-based measures as a proxy for Quality and Cost performance category scores for hospital-based eligible clinicians
• Urged CMS to approve QCDR measures by December 1 prior to the reporting year
• Commended the Agency for including “PSH Care Coordination” as an Improvement Activity.

ASA is excited about this PSH recognition, pending finalization, that will allow the work of PSH sites to be rewarded as early as next year in the MIPS program.

Read the full letter here.

Read the QPP Rule here.

For more information, please visit the ASA MACRA webpage.