ACP Urges CMS to Extend Flexibilities in the Quality Payment Program Due to the COVID-19 Crisis

Washington, DC (June 12, 2020) Today, in a letter sent to Administrator of the Centers for Medicare & Medicaid Services (CMS), Seema Verma, the American College of Physicians (ACP) offered recommended actions for the agency to take to further protect clinicians against the long-term effects of the COVID-19 public health crisis in the context of the Quality Payment Program (QPP). In the interest of not jeopardizing progress being made in the move toward value-based payment, ACP asked that the flexibilities put in place for COVID-19 be extended at least through 2021 in order to ensure the future success of the QPP.

“It is imperative CMS take further action to protect clinicians against the longer-term impacts of the COVID-19 crisis. Not doing so could jeopardize the progress of value-based payment reform efforts,” wrote Jacqueline W. Fincher, MD, MACP, president, ACP.

The letter to CMS outlined several existing flexibilities that should be extended plus additional actions to take to further protect clinicians from the long-term impacts that the COVID-19 PHE will have on the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

Among other recommendations, ACP urges CMS to:

  • Automatically hold eligible clinicians harmless from 2020 MIPS penalties;
  • Delay mandatory implementation of the new MIPS Value Pathway until 2024 at the earliest;
  • Freeze removal and introduction of new mandatory MIPS measures for PY 2021;
  • Adjust measure specifications and benchmarks, MIPS performance thresholds, risk adjustment, patient attribution, financial benchmarking, and target pricing as necessary;
  • Hold APM participants harmless from downside risk for PY 2020;
  • Do not use flawed 2020 data to negatively adjust APM payments;
  • Allow all APM participants to extend their current contracts by one year; and
  • Expediently develop more APMs, particularly those that offer fixed, prospective payments.

“If CMS does not act quickly, we risk losing a substantial amount of the hard work, investment, and progress gained under the value-based payment reform movement, particularly risk-bearing APMs, that will far outweigh any short-term concessions,” explained Dr. Fincher. “The technical conclusion of the PHE does not mark the end of the impacts of COVID-19, but rather, the beginning of a long, arduous rebuilding process. COVID-19 flexibilities should remain in effect through the end of 2021, or until vaccines or treatments for COVID-19 are widely available.”

View the full letter here.

Contact: Taneishia Bundy, (202) 261-4523,

About the American College of Physicians

The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 159,000 internal medicine 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 illness. Follow ACP on Twitter, Facebook, and Instagram.