February 13, 2023

APMA submitted comments to CMS on February 13, expressing our significant concerns about the limitations of MIPS measures available to podiatrists. These comments were in response to CMS’ MIPS 2024 PY Call for Measures. Specifically, APMA is concerned that CMS does not realize how difficult it has become for a podiatric physician to score sufficiently high enough in the Quality Performance Category to meet the performance threshold when using the Podiatry specialty set. Read this letter at www.apma.org/CommentLetters.

Given that many if not all podiatric physicians are not scored in the Cost performance category, and many practices take the small practice EHR exception, an increased weight is placed on the quality performance category. These reweighting scenarios leave podiatric physicians with very little room for error in terms of avoiding a penalty.

APMA asked that CMS maintain the small practices accommodations already in place, as well as make MIPS data more accessible and easier to understand and navigate so that specialties can better prepare their clinicians for participation. In addition to this comment letter, APMA plans to seek a meeting with CMS, so as to better address this ongoing concern and work towards a solution for our members.

To find all up-to-date information on the 2023 MIPS performance year, visit www.apma.org/MIPS2023. Contact us with questions via MIPS@apma.org.

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