PCPCC Responds to CMS Request for Information on Alternative Payment Models and the Merit-based Incentive Payment System

On November 17th, the Patient-Centered Primary Care Collaborative (PCPCC) responded to the Center for Medicare and Medicaid Services Request for Information (RFI) regarding "Implementation of the Merit-Based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models". In the letter, the PCPCC advocates for measurement harmonization, describes the need for multiple pathways for practices to be recognized as "certified medical homes" under MACRA, and underscores the need to reevaluate the definition of "nominal risk."