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MACRA Cost Measures: Call for Public Comment for Total Per Capita Cost (TPCC) Measure Re-evaluation

Project Title: MACRA Cost Measures: Call for Public Comment for Total Per Capita Cost (TPCC) Measure Re-evaluation

Dates: The Call for Public Comment period opens on April 25, 2024 and closes on May 17, 2024.

Project Overview:

The Centers for Medicare & Medicaid Services (CMS) has contracted with Acumen, LLC to develop and maintain cost measures for potential use in the Merit-Based Incentive Payment System (MIPS) to meet the requirements of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The contract name is “Physician Cost Measures and Patient Relationship Codes (PCMP).” The contract number is 75FCMC18D0015, Task Order 75FCMC19F0004. As part of the measure maintenance process, Acumen requests interested parties to submit comments on the comprehensive re-evaluation of the Total Per Capita Cost (TPCC) cost measure. Acumen is seeking input from the public on the TPCC measure specifications to determine potential refinements for the measure to better evaluate the overall cost of ongoing care management.

Additional Resources:

You may access the document in the list by clicking its title:  

For more information on the current TPCC measure in use in MIPS, please refer to the 2024 Measure Information Form and Codes List. Additional information about cost measure development and re-evaluation is available on the CMS.gov QPP Cost Measures Information page.

Project-Specific Instructions:

The Total Per Capita Cost (TPCC) measure is undergoing comprehensive re-evaluation after three years in the MIPS program to address stakeholder inquiries and to ensure the measure is functioning as intended. The TPCC measure was respecified and added to the MIPS cost performance category in performance year 2020. Comprehensive re-evaluation allows interested parties to submit comments on how the measure should be updated. During comprehensive re-evaluation, we will consider feedback gathered through the public comment process and conduct additional information gathering and testing to determine changes to the measure. 

This is the second round of public comment we are seeking on the comprehensive re-evaluation of the TPCC measure. The first round was held in July 2023 and covered 10 episode-based cost measures (EBCMs) and two population-based cost measures, including the TPCC measure. The goal of this public comment period is to obtain input on the TPCC measure’s attribution methodology and address stakeholder concerns over the attribution of advanced care providers (i.e., nurse practitioners [NP], physician assistants [PA], and certified clinical nurse specialists [CNS]) in specialty practices. 

To submit feedback, interested parties should submit a response to the online survey by 11:59 p.m. Eastern Time on May 17, 2024: https://acumen.qualtrics.com/jfe/form/SV_1M7FjrBOi5o41h4. Respondents can also attach a PDF or Word document with their comments.

If you have questions about the TPCC measure, the public comment process, or comprehensive re-evaluation, please contact macra-cost-measures-info@acumenllc.com

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