MGMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed 2020 Medicare Physician Fee Schedule. MGMA recommended that CMS:
· Finalize the proposal to maintain separate payment rates for E/M visit levels;
· Develop the Merit-based Incentive Payment System (MIPS) Value Pathways proposal through continued stakeholder input;
· Stabilize the MIPS quality performance category by maintaining current data completeness thresholds for longer than a single performance year;
· Prioritize improvements to the MIPS cost performance category before increasing its weight; and
· Increase opportunities to participate in Advanced Alternative Payment Models.