American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

ACS Comments on CY 2020 Quality Payment Program Proposals

The American College of Surgeons (ACS) submitted comments September 26 to the Centers for Medicare & Medicaid Services (CMS) regarding proposed policies for the calendar year (CY) 2020 Quality Payment Program, which are included in the CY 2020 Medicare Physician Fee Schedule proposed rule. As part of the proposed rule, CMS included a Request for Information (RFI) on Merit-based Incentive Payment System (MIPS) Value Pathways (MVP). The MVP is intended to streamline MIPS reporting by limiting the number of required measures to best assess the quality and value of care for a particular specialty or condition to allow for an easier transition to Alternative Payment Models (APMs). The program aims to connect measures and activities across the four MIPS performance categories, incorporate a set of administrative claims-based population health quality measures, provide meaningful data and feedback to clinicians, and enhance information to patients.

The ACS supported the concept of MVPs and offered recommendations for the development and testing of condition or episode-based surgical MVPs. The ACS also advocated for MVPs based on clinical service lines, rooted in a surgical verification program with conformance measures to track avoidable harms, that include patient-reported outcome measures, and provide resources to understand the costs involved in an episode of care.

In addition to the MVP RFI, the ACS commented on the Quality, Cost, Improvement Activities, and Promoting Interoperability (PI) performance categories, as well as Advanced APMS and several additional RFIs related to health information technology (IT). The ACS encouraged CMS to use measures and improvement activities that promote a culture of continuous quality improvement and provide meaningful data for surgical practice, to develop actionable cost measures that allow surgeons to understand total cost of care, and to foundationally change the PI category to reward the advanced use of health IT.

The full text of the ACS comments is available here. For any additional questions or comments, contact

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