Regulatory Advocacy

The AAO-HNS has a long history of working closely with regulatory agencies (e.g., Centers for Medicare & Medicaid Services, U.S. Food and Drug Administration) to maintain our visibility and credibility with national representatives regarding federal regulatory issues.

We believe that advocacy is the key to defining the future of otolaryngology. Federal regulatory advocacy is a top priority of the AAO-HNS.

Academy Comments to CMS on MIPS and APM Proposed Rule
On Monday, the Academy submitted comments to Centers for Medicare & Medicaid Services (CMS) in response to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Proposed Rule. The Academy commented on the consolidation of existing quality programs into MIPS; the accelerated reporting timeline for physicians; RegentSM and quality measure reporting mechanisms; the complexity of the MIPS scoring system; and the restrictive Advanced APM definition. Access the comments.

Academy Meets with CMS to Discuss MIPS and APMs
On Wednesday, May 18, Academy staff met with CMS officials to discuss the proposed Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) programs. Members are currently scheduled to begin reporting for the MIPS and APM programs on January 1, 2017.

Academy staff and CMS officials discussed key policy topics including: the rapid implementation of the MIPS and APM programs with little time for preparation and necessary education; the complexity of the MIPS scoring system; Qualified Clinical Data Registry (QCDR) criteria and measures; and the restrictive Advanced APM definition that will preclude many specialists from qualifying for the new APM program. The Academy also requested that CMS offer educational and technical assistance for specialties societies and physicians to facilitate the shift from traditional Medicare reporting to reporting for the MIPS and APM programs.

The Academy also stated while the MIPS and APM programs are a positive step, CMS should continue to work with the Academy towards a system of payment innovation that would allow the greatest possible number of physicians to not only participate, but succeed. The Academy is currently working on formal comments for CMS. Once the comments are submitted to CMS comments will be made available to all Members.

Learn more about the new MIPS and APM programs.