Prior to Implementation of MACRA, Physician Groups Request CMS to Address Administrative Burden of Legacy Physician Quality Programs for 2018

On March 21, 2017, the American Medical Association and 86 state and specialty medical societies submitted a letter requesting the Centers for Medicare and Medicaid Services (CMS) reduce the administrative burden and provide for hardship exemptions for the three legacy physician quality programs: Meaningful Use (MU), Physician Quality Reporting System (PQRS) and the Value-based Modifier (VM) in 2018, their final year. Under the new Merit-based Incentive Payment System (MIPS), separate adjustments for these three programs will sunset December 31, 2018.

Specifically the letter requested that CMS:

  • Establish a new “Administrative Burden” category of hardship exemption for the 2016 MU performance year;
  • Create a hardship exemption for physicians who attempted to report PQRS in 2016 but were unsuccessful due to the complexity of the reporting requirements and the significant number of measures that were required; and
  • Exempt from additional penalties under VM any physician who avoided the PQRS penalty in 2018.


In closing, the letter indicated that the signatories were open to other options to achieve the overall goal of reducing the administrative burden of MU, PQRS and VM.

Click here to access the McDermottPlus MACRA Resource Center.

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