Internists Offer Recommendations to CMS' Proposed Medicare Quality Payment Program Rule

Alternatives based on five guiding principles and their details

Washington, D.C. (August 22, 2017)—The American College of Physicians (ACP) offered its recommendations for improvements to the proposed rule to implement the Quality Payment Program (QPP), as established by the Medicare Access and CHIP Reauthorization Act (MACRA), in a letter submitted last night to the Centers for Medicare and Medicaid Services (CMS) Administrator, Seema Verma.  If accepted by CMS, ACP’s recommendations would simplify the scoring approach for the QPP, improve performance reporting requirements, reduce the administrative burden, provide even more opportunities for small practices to succeed, and increase options for patient-centered medical home and patient-centered specialty practices.  ACP’s specific recommendations are aligned with five guiding principles that the 152,000-member organization recommended CMS consider as it finalizes the rule:

  • ACP reiterates its call for CMS to use the opportunity provided through the new MACRA law to build a learning health and healthcare system. Also important is the need to constantly monitor the evolving measurement system to identify and mitigate any potential unintended consequences.
  • ACP strongly recommends CMS collaborate with specialty societies, frontline clinicians, patients, and electronic health record (EHR) vendors in the development, testing, and implementation of measures with a focus on integrating the measurement of and reporting on performance with quality improvement and care delivery and decreasing clinician burden.
  • ACP recommends that CMS work to ensure that patients, families, and the relationship of patients and families with their physicians are at the forefront of the agency’s thinking in the development of both the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM) pathways, including the development and implementation of the performance measures to be used within these programs.
  • ACP strongly recommends that CMS consider the detailed recommendations to reduce administrative tasks and requirements outlined in our recent position paper, Putting Patients First by Reducing Excessive Administrative Tasks in Health Care, and summarized in our post-publication outreach letter to CMS, and continue to work with physicians and other key stakeholders to achieve the goals of putting patient care first by reducing administrative complexities and burdens.
  • ACP recommends enhancement of patient-centered medical homes and patient-centered specialty practices.

“It is critically important to recognize that the legislative intent of MACRA is to truly improve care for Medicare beneficiaries and thus, the policy that is developed to implement the Medicare Quality Payment Program must be thoughtfully considered in that context,” said Jacqueline W.  Fincher, MD, MACP, chair of ACP’s Medical Practice and Quality Committee and a practicing physician in Georgia. “Our comments to CMS offer concrete suggestions on how to simplify reporting of performance measures and activities and provide more choices and opportunities for all internal medicine physicians to be successful, no matter what their practice size or structure.”

Within the letter, ACP not only highlights its top priority recommendations, but also provides specific and detailed comments.  These comments pertain to the four components of the Merit-Based Incentive Payment System (MIPS) pathway—Quality, Advancing Care Information, Improvement Activities, and Cost—as well as to the advanced Alternative Payment Model pathway within the QPP.


The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 152,000 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 and Facebook.

Contact: David B. Kinsman, APR 202-261-4554,