Submitted via e-mail to: https://www.regulations.gov
Re: RIN 0938–AT13; Medicare Program; CY 2018 Updates to the Quality Payment Program
Dear Ms. Verma:
The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare & Medicaid Services (CMS) on the updates to the quality payment program.
ACAP is an association of 60 not-for-profit, community-based Safety Net Health Plans located in 29 states. Our member plans provide coverage to over seventeen million individuals enrolled in Medicaid, Children’s Health Insurance Program (CHIP) and Medicare Advantage Dual-Eligible SNPs. Nationally, ACAP plans serve approximately one-third of all Medicaid managed care enrollees. Eighteen of our plans are D-SNPs and 14 of our plans participate in the Financial Alignment Demonstration.
Please find below ACAP’s comments on the criteria for the Other Payer Advanced APM.