Anatomy IT asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting in comments submitted on both the 2027 Quality Payment Program (QPP) (opens in a new tab) and the 2027 ASC Quality Reporting (ASCQR) (opens in a new tab) proposed rules.
See our previous blogs for a summary of the proposed changes to the QPP (opens in a new tab) and the ASCQR program (opens in a new tab) in 2027.
Quality Payment Program Comments
In our response to the 2027 QPP proposed rule, we focused on challenges that our clients currently face under MIPS and potential issues that could be caused by the proposed changes.
- In the Quality section, we:
- Continued to advocate for our specialty and subspecialty clients, as measure options remain limited for these providers. We emphasized the need for a comprehensive set of specialty- and subspecialty-specific measures to accurately reflect the quality of care delivered by these physicians.
- Expressed concern for the proposal to require MIPS Core Measure reporting, as this would further restrict measure choice.
- We supported the proposal to exempt small practices from Core Measure reporting, if this requirement is finalized.
- We also supported the proposal to implement flat benchmarking for Core Measures that would otherwise be capped at 7 points.
- In the Improvement Activities (IA) section, we:
- Advocated for small practices by encouraging CMS to maintain special scoring in future years.
- In the Promoting Interoperability (PI) section, we:
- Opposed CMS’ proposal to remove the Security Risk Analysis (SRA) measure from the MIPS PI category. Although the SRA would still be required under HIPAA, including it in MIPS is important for ensuring the SRA is completed annually.
- Requested a phased approach to the implementation of the new Electronic Prior Authorization measures to ensure that appropriate systems are in place before making participation mandatory for physicians.
- In the Cost section, we:
- Advocated for increased transparency in measure development, more substantive information in feedback reports, and greater clarity in measure specifications.
- Urged CMS to implement specialty attribution exclusions for episode-based cost measures to ensure that only clinicians directly responsible for the care of a condition or procedure are assigned the associated costs. This would mirror the exclusions in the Total Per Capita Cost (TPCC) measure.
- In the MIPS Value Pathways (MVPs) section, we:
- Strongly opposed CMS’ proposal to “sunset” traditional MIPS in 2029, as we believe a fee-for-service model will always be valuable, and because the limited measure choice in MVPs is a serious concern for specialists and subspecialists.
- Advocated for increased measure choice in MVPs, particularly for subspecialists.
- Responded to CMS’ request for feedback on MVP scoring: we recommended that CMS focus on expanding measure choice within MVPs rather than relying on scoring changes to achieve meaningful comparisons.
ASCQR Program Comments
In this rule, CMS proposed the removal of one measure and requested feedback on the modification of one measure.
Proposed Removal of ASC-9: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients
We supported the removal of this measure, as we agree with CMS’ rationale that this measure focuses on documentation, rather than a patient outcome. The existing Facility 7-Day Risk-Standardized Hospital Visit Rate after Outpatient Colonoscopy is better suited to address whether appropriate clinical care was delivered.
Request for Feedback on Stratification of ASC-4: All-Cause Hospital Transfer/Admission
We supported modifying this measure to incorporate phases of care and encouraged CMS to adopt a framework that would differentiate between preoperative transfers and transfers occurring during or after surgery. This differentiation is particularly important for ophthalmology-specific ASCs because a significant proportion of hospital transfers from these ASCs are identified before surgery begins and may reflect a patient’s underlying medical condition rather than a procedural complication.
We also asked CMS to minimize ASC burden by relying on information that ASCs already routinely document as part of standard clinical workflows, rather than introducing additional documentation requirements.
Next Steps
- Missed our webinar (opens in a new tab) on the 2027 MIPS proposed changes? It’s not too late to catch up! Contact us (opens in a new tab) to gain access.
- Share this information with your colleagues.
- If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
- If you are not an Anatomy IT client, contact us (opens in a new tab) to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
- Stay tuned for our blogs on the finalized MIPS and ASCQR requirements later this fall.
If you have any questions, let us know!
Written By: Sarrah Hakim, MHSA
About the Author: Sarrah is a health policy professional with experience in healthcare operations, performance measurement, and policy implementation. She holds a Master of Health Services Administration from the University of Michigan, where she focused on health policy and system performance. Her work with organizations such as Cleveland Clinic and Michigan Medicine has given her firsthand experience with quality reporting, patient experience initiatives, and operational challenges health systems face under programs like MIPS. She is committed to helping healthcare professionals navigate the complexities of regulatory reporting with clarity and confidence.