ASRA Provides Formal Comments on MIPS and APM

Jun 27, 2016

ASRA, along with six other national member associations dedicated to the treatment of patients with chronic, intractable pain, has provided comments to the Centers for Medicare and Medicaid Services (CMS) regarding its Quality Payment Program (QPP) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

The QPP involves two pathways: the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) proposed rule. In providing its comments, the pain organizations outlined 11 specific points intended to create a fairer and less burdensome process for pain physicians. The organizations specifically identified concerns for solo and small practice practitioners and regarding the identification of "non-patient facing" clinicians, among other concerns.

ASRA along with its partner societies will be meeting with CMS in the near future to further discuss these recommendations. The final ruling is due out on or around November 1st.

We will continue to keep you informed about progress in this key area as we advocate for the safe and efficient practice of pain medicine.


The seven organizations that authored the formal comments letter are tied together by the nature of their members' patients being typically "referred from primary care physicians, surgeons, neurologists, oncologists, or other specialties after not achieving significant improvement in quality of life with the use of other forms of treatment such as oral medications, surgery, physical therapy, chiropractic care, other nonpharmacologic, or intervention services." 

  • American Academy of Pain Medicine
  • American Academy of Physical Medicine and Rehabilitation
  • American Society of Anesthesiologists
  • American Society of Interventional Pain Physicians
  • American Society of Regional Anesthesia and Pain Medicine
  • North American Neuromodulation Society
  • Spine Intervention Society