The CME Coalition has submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the agency's final rule regarding the definition of practice improvement activities in the implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Following the Coalition's comments on the proposed rule, the Coalition again asks that CMS continue to explore the potential role that continuing medical education (CME) can play as a clinical practice improvement activity. In its final rule, CMS acknowledged public comments encouraging the inclusion of CME as an improvement activity under the MACRA regulatory regime, and the CME Coalition hopes to work with CMS in order to include CME in the 2018 proposed fee schedule. In explaining its request, the CME Coalition notes that CME is "a leading means by which physicians, develop and maintain the knowledge, skills, and practice performance that leads to imporved performance and optimal patient outcomes."

The comments in full are available below.

Yesterday, the Centers for Medicare and Medicaid Services (CMS) posted a revised FAQ on its Open Payments website regarding the reporting of CME-related payments. The revised FAQ 8165, which is provided below, replaces an earlier FAQ on the same subject by providing greater specificity with regard to the exclusion of certain CME-related payments from Sunshine Act reporting that meet the standards outlined by CMS. We believe that while this FAQ is fully consistent with our earlier interpretation of the status of independent CME-related payments when CMS revised the regulations in 2014, as well as the interpretation of other leading stakeholders like the American Medical Association, the revised FAQ now provides even greater clarity to stakeholders. 

Several hundred leading healthcare practitioners, plus scores of stakeholder groups representing millions of the nation’s healthcare providers, submitted comments in support of encouraging the use of accredited CME to improve the quality of healthcare under the new Merit-Based Incentive Payment System (MIPS), according to analysis conducted by the CME Coalition. Over 300 endorsements for CME were submitted in response to CMS’ call for public comment on implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), including comments from leading physician groups, CME providers, and other stakeholders.​

In a letter to Sen. John Barrasso (R-WY), the American Medical Association and dozens of specialty groups and state medical societies offered their support to legislation sponsored by the Wyoming senator that would exempt continuing medical education (CME) activities from Sunshine Act reporting requirements. The groups urge prompt passage of the legislation, citing confusion around Centers for Medicare and Medicaid Services (CMS) rules and the effect those rules have on the publication of medical textbooks and peer-reviewed journals.