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Proposed Rule Looking for Feedback on the CAHPS for ACOs/MIPS Programs

August 15, 2019

CMS published the proposed rule for the CY 2020 Physician Fee Schedule in the Federal Register on August 8, 2019. CMS is currently seeking public comment on a few items that would impact both the CAHPS for ACOs and CAHPS for MIPS programs.

CAHPS for ACOs Quality Score

For calendar year 2018, the CAHPS for ACOs and CAHPS for MIPS studies were standardized with matching surveys. Even though the surveys now match, the reporting measures for calculating performance differ. The CAHPS for ACOs program currently allocates up to 2 points per pay for performance measure based on how well an ACO performs compared to benchmark deciles. The CAHPS for MIPS scoring system assigns points for each measure, then points for all scored measures are averaged to calculate the overall score. In the proposed rule, CMS would like public comment on using the CAHPS for MIPS scoring methodology for both the CAHPS for ACOs and CAHPS for MIPS surveys.

Narrative Elicitation Protocol (NEP)

The NEP is a set of five open-ended questions the Agency for Healthcare Research and Quality (AHRQ) has been testing on the Clinician & Group (CG) CAHPS survey. The CAHPS for MIPS program is built on the CG-CAHPS base, and CMS is now seeking comment on adding open-ended questions to the CAHPS for MIPS program. Specifically, they are accepting comments on the following:

  • How free text may be scored in the Quality Payment Program (QPP)
  • The value of collecting data on narrative (open-ended) questions
  • Concerns about the burden involved with collecting responses
  • If clinicians would find this information valuable
  • Should these questions collect data at the individual eligible clinician level or group level?

Public Comment Period

CMS is interested in stakeholder feedback to proposed rules. Comments on responses CMS receives are addressed in the published final rule. To provide feedback on the CY 2020 Physician Fee Schedule proposed rule, please submit comments to www.regulations.gov by 5pm on September 27, 2019.

For more general information about CAHPS for ACOs and CAHPS for MIPS click here.