The AHA today submitted several overarching recommendations for the Merit-based Incentive Payment System and alternative payment models in response to the Centers for Medicare & Medicaid Services’ request for comments to inform implementation. The MIPS and APMs constitute the two tracks of the new physician payment system mandated by the Medicare Access and CHIP Reauthorization Act of 2015, and will affect Medicare physician fee schedule payments beginning in 2019. With respect to the MIPS, AHA urged CMS to adopt a system that “measures providers fairly, minimizes unnecessary data collection and reporting burden, focuses on important quality issues, and promotes collaboration across the silos of the health care delivery system.” Among other comments, AHA urged CMS to implement the APM provisions in a manner that provides the greatest opportunity for physicians to become qualified APM participants. “Lastly, the AHA applauds CMS for seeking early input from the field on the design of the MIPS and APMs,” wrote Ashley Thompson, AHA senior vice president for public policy analysis and development. “We strongly encourage the agency to provide as much opportunity as possible for ongoing stakeholder input.”