Earlier this summer, CMS and third-party contractor, Ketchum, Inc., shared a draft Podiatry MIPS Value Pathway (MVP) concept with APMA for review and feedback. APMA reviewed the draft Podiatry MVP, met with CMS and Ketchum representatives, and recently provided written response regarding the draft MVP. While APMA is generally supportive of the development of an MVP with hopes of reducing administrative burden on podiatrists, the current draft MVP may not fit the bill. In our response to CMS, APMA:
- supports continued automatic reweighting of the Promoting Interoperability Performance Category for “small practices”
- supports the inclusion of specific measures, including qualified clinical data registry (QCDR) measures, that are potentially meaningful to podiatric practice and allow for greater choice in MVP participation
- relates concern over administrative burden and poor scoring potential, specifically related to Medicare Part B Claims Collection Type quality measures and quality measures with benchmark scoring limitations
- opposes making MVPs mandatory in future performance years
APMA has made clear recommendations regarding the draft Podiatry MVP, including for CMS to:
- remove the topped-out status and scoring limitations on all quality measures in the MVP
- extend the new measure scoring floor to measures that were introduced into the program prior to the adoption of the policy
- allow for choice in the MIPS program by refraining from making MVPs mandatory in future performance years
- consider the administrative and financial burdens participation in MIPS has on providers
- modify quality measure and improvement activity options within the Podiatry MVP
Read this and all past comment letters in full at www.apma.org/commentletters. If you have questions or concerns, contact the APMA Health Policy and Practice department at healthpolicy.hpp@apma.org.
%20(1).jpg)
