News & Press: General News

CCTS CMS Comments

Tuesday, November 17, 2015  
Posted by: CR Forum Staff
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November 17, 2015

Andrew M. Slavitt
Acting Administrator
Centers for Medicare & Medicaid Services,
Department of Health and Human Services,
Room 445-G, Hubert H. Humphrey Building,
200 Independence Avenue SW., Washington, DC 20201

Dear Acting Administrator Slavitt,

Thank you for your leadership on patient care issues. We write you today on behalf of the clinical and translational medical research community in response to the recent Request For Information issued by the Centers for Medicare and Medicaid Services (CMS) entitled, Implementation of the Merit-Based Incentive Payment System, Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models (Docket no: 2015-24906).

The Coalition for Clinical and Translational Science (CCTS) includes both the Association for Clinical and Translational Science and The Clinical Research Forum and serves as the unified voice of the clinical and translational research community representing the majority of major biomedical research center in the US. We act as a nationwide, grassroots network of scientists and academic and healthcare leaders who work together to educate Congress and the administration about the value and importance of federal clinical and translational research and of research training and career development activities. CCTS’s goals are to ensure that the full spectrum of medical research is adequately funded, translating from the bench, to the bedside, to practice, to public benefit and policy, with real impact on health. We also support a regulatory and public policy environment facilitates ongoing expansion and advancement of the field of clinical and translational science.

In regards to this RFI, our interests pertain to Clinical Practice Improvement Activities and the solicitation of specific criteria (Section 5). Consistent with other stakeholders, we ask CMS to acknowledge that physicians should receive credit for teaching as participation in research for clinical practice improvement activities. Doing research that improves care, engaging in research process improvement using quality improvement (QI) methods, and teaching physicians how to do research all contribute to the improvement of clinical practice, and should receive clinical practice improvement activity credit for those who take this important work on. Of note, this work is often funded by the National Institutes of Health and other federal entities and intended to promote patient wellness and improve public health. As CMS works to define Clinical Practice Improvement Activities, please acknowledge academic physician-researchers and others who are already undertaking and involved in care improvement activities of national significance.

Thank you for your time and your consideration of this request.


Rebecca D. Jackson, MD
Association for Clinical and Translational Science

Harry Selker, MD, MSPH
The Clinical Research Forum
Association for Clinical and Translational Science