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.