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Commitment to Collaboration: PCPI's Regulatory Comment Process

Tuesday, October 9, 2018   (0 Comments)
Posted by: Bevin Rousopoulos
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October 9, 2018

Committed to Collaboration:

How PCPI’s regulatory comment process directly engages members and stakeholders



“Regulators and ultimately legislators are more likely to respond to the real-world concerns and experiences of clinicians in the field. Our advocacy efforts are further strengthened by our multistakeholder membership working together to improve quality for patients. PCPI will continue to expand this new engagement process and we look forward to broad participation in upcoming comment letters,” Kevin Donnelly, CEO, PCPI.

Informed public comments on proposed federal rules are one of the most powerful ways PCPI stakeholders can influence public policy. With this year’s comments on HHS’ proposed rule for the 2019 Quality Payment Program (QPP), PCPI successfully implemented a new process designed to directly involve members.

Beginning with CMS issuing the proposed rule for QPP year 3 in July, PCPI’s new process involved:

  • Offering PCPI members and stakeholders an opportunity to provide input on PCPI’s comment letter through August 10
  • A virtual forum exclusively for members and stakeholders to discuss their submissions on August 16
  • PCPI incorporates member and stakeholder input into comment letter submitted to CMS September 10. Read PCPI’s comment letter.

Members and stakeholders from many specialties submitted suggestions and attended the forum, substantially strengthening the detail and impact of PCPI’s comments. More significantly, the process helped focus the comments on issues most important to members, such as measure licensing and proposals for early elimination of “topped-out” measures.



While these comments do not guarantee that HHS will make the changes requested, they do make it possible and are an important part of an overall strategy for engaging regulators at every step of policy development and implementation. Another step in this strategy will take place at the PCPI Fall Conference 2018 on October 17-18. CMS and industry leaders will join forces to examine the future of QPP and how it can be made a more effective quality improvement program. For more information and to register click here.


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