ACP Response to CMS's Request for Information: Certification Frequency and Requirements for Reporting of Quality Measures Under CMS Programs

Letter also offers ACP recommendations

Washington, DC January 27, 2016 -- The American College of Physicians (ACP) today sent a letter to Andy Slavitt, acting administrator of the Centers for Medicare & Medicaid Services (CMS), responding to CMS's request for information on the certification frequency and requirements for reporting of quality measures under CMS programs [CMS-3323-NC].

The letter, from Peter Basch, MD, MACP, chair of ACP's Medical Informatics Committee, also offered recommendations from ACP. Three key recommendations are:

  • The problems with eMeasures cannot be fixed via the certification process. Instead, a fix may be in order for the measure development process and the measures themselves.
  • CMS should only approve eMeasures that meet stringent requirements for data elements that are readily available in common EHR systems, and that are reasonably collected during the course of care delivery.
  • ACP urges CMS to focus immediately on evolving all of the current quality measurement programs to truly align in preparation for the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) pathways.


ACP is the largest physician medical specialty society, and the second largest physician-membership organization, in the United States. ACP members include 143,000 internal medical physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illnesses.