As a result of our conversations during past CME Coalition monthly meetings on the subject, the CME Coalition submitted public comments today in response to certain proposed policies included in the Centers for Medicare and Medicaid Services’ (CMS) proposed rule on the Medicare Physician Fee Schedule for calendar year (CY) 2023.
The CME Coalition expressed our strong support for the addition of national CME accrediting organizations and providers as new third-party intermediaries able to directly report clinician completion of accredited CME and/or Maintenance of Certification (MOC)
improvement activities for the Merit-based Incentive Payment System (MIPS) Value Pathways. As discussed in more detail in the attached letter, we communicated that we believe the inclusion of CME organizations as a third-party intermediary in this capacity would allow for reduced clinician burden as well as a heightened clinician focus on patient care, particularly with regard to metrics of priority to CMS.
The CME Coalition expressed our strong support for the addition of national CME accrediting organizations and providers as new third-party intermediaries able to directly report clinician completion of accredited CME and/or Maintenance of Certification (MOC)
improvement activities for the Merit-based Incentive Payment System (MIPS) Value Pathways. As discussed in more detail in the attached letter, we communicated that we believe the inclusion of CME organizations as a third-party intermediary in this capacity would allow for reduced clinician burden as well as a heightened clinician focus on patient care, particularly with regard to metrics of priority to CMS.
"Consistent with their core mission, accredited CME providers have acted to support their clinician learners in several ways, including by: (1) helping clinicians to understand how to identify improvement activities, facilitate those activities, and assist clinicians in attesting to their participation; and (2) planning and presenting CME activities that will count as improvement activities. Because CME providers are already guiding clinicians through this process, these organizations are well positioned to serve as a third-party intermediary to submit data on clinician completion of CME or MOC activities within the improvement activities performance category."
| final_cms_comment_letter_-_cme_coalition_-_medicare_qpp1.pdf |
