CMS Requests Comments on Draft Episode Groups, Trigger Codes and Proposed Framework for Cost Measures

March 20, 2017


CMS is accepting comments until April 24, 2017, on draft episode groups, trigger codes and a proposed framework for cost measures. The Merit-based Incentive Payment System (MIPS) measures clinicians’ performance in four areas: quality, clinical practice improvement activities, advancing care information (i.e., meaningful use of certified electronic health record technology or CEHRT), and cost (i.e., resource use).


This request for comments is focused on supporting the agency’s development of cost measures for the Cost Performance Category. In 2019, the first year that payment adjustments will be made under MIPS, CMS will not implement the Cost Performance Category, but the agency intends to begin adjusting payments under this category beginning in 2020 when it will be weighted at 10 percent of the total MIPS score in 2020 (adjustments will increase to 30 percent in 2021.

Two key components of cost measures will be episode groups (i.e., defining the episode of care) and trigger codes (i.e., identifying codes that start the episode). In this outreach, CMS is seeking comment on 117 episode groups and their associated trigger codes. CMS is planning to use three categories of episode groups: Acute Inpatient Medical Condition, Chronic Condition and Procedural groups. CMS also is requesting comments on the proposed general framework for the development of cost measures.

More information on this request for comments is available here.

Click here to access the McDermottPlus MACRA Resource Center.

For more information please contact Sheila Madhani at 202-204-1459 or

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