November 17, 2015
Centers for Medicare & Medicaid Services
U.S. Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G
Washington, DC 20201
SUBJECT: CMS-5516-P Request for information regarding implementation of the merit-based incentive payment system, promotion of alternative payment models, and incentive payments for participation in eligible alternative payment models
Dear Mr. Slavitt:
On behalf of The Hospital & Healthsystem Association of Pennsylvania (HAP), which represents approximately 240 member institutions, we appreciate the opportunity to provide comments about the request for information that will assist with the implementation of the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Models (APM).
With nearly two-thirds of physicians being employed or under contract by hospitals and health systems in Pennsylvania, HAP member hospitals and health systems represent a key constituency of health care providers affected by changes related to the Medicare Access and CHIP Reauthorization Act of 2015.
HAP commends CMS for requesting input into the implementation of the MIPS and APMs and urges the Centers for Medicare & Medicaid Services (CMS) to implement these programs in expansive ways with specific attention paid to the administrative burden of any requirements. The attached document provides high-level principles for CMS to consider while developing the details of these programs.
Thank you for your consideration of HAP’s comments. If you have any questions, contact me at (717) 561-5325, or Kate Slatt, senior director, health care finance policy, at (717) 561-5317.
Sincerely, Jeffrey W. Bechtel
Senior Vice President, Health Economics and Policy