MIPS/MACRA Letter

In June, AAPCHO submitted comments to the Centers for Medicare and Medicaid Services (CMS) on their new Quality Payment Program (QPP), which includes a Merit-Based Incentive Payment System (MIPS) and the potential to develop Alternative Payment Models (APMs). The QPP was developed under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MIPS help CMS assess health professionals’ quality of care, use of resources, innovation in clinical practices, and adaptation of Meaningful Use within Electronic Health Records. APMs help to provide CMS with another mechanism with which to see how providers are paid for care.

These payment mechanisms are not applicable to FQHCs. AAPCHO’s comments reiterate the importance of preserving PPS, and state how FQHCs are ineligible for the proposed incentive programs because of their payment structure. AAPCHO and NACHC proposed for CMS to accept voluntary data on MIPS from FQHCs, in order for CMS to do comparisons of quality and value across providers. AAPCHO’s comments also stressed the need and importance of collecting data on the social determinants of health (SDOH) and enabling services, and offered guidance on the best way to capture this data in the future.