CMS and its contractor, Acumen, LLC, are gathering input on episode groups to consider for Wave 4 of Merit-based Incentive Payment System (MIPS) cost measure development through a Call for Public Comment. Stakeholders are invited to submit their feedback in response to the information and questions included in the document between now and February 5, 2021, at 11:59 p.m. Eastern Time.

Where can stakeholders learn more about the public comment period?

A recording of the MACRA Wave 4 Cost Measure Development presentation is available on the Quality Payment Program Webinar Library. The goal of this recording is to provide detailed information about the Wave 4 public comment approach.

Why use a public comment approach?

CMS and Acumen are using a public comment approach to solicit input on which measures to prioritize for Wave 4 development instead of the traditional Clinical Subcommittee (CS) approach. We understand that 2020 has presented new challenges and clinicians and specialty societies have expressed concern about their limited bandwidth during this time. The public comment approach allows for broader and more flexible stakeholder participation.

Where can stakeholders access the public comment materials and provide feedback?

Stakeholders may access the public comment materials on CMS’s Currently Accepting Comments Page. The following documents are available for stakeholders to download and review:

To submit feedback, stakeholders may either: (i) email a comment letter to, or (ii) submit a response to the Wave 4 Measure Development Survey:

How will the public comment process work?

CMS and Acumen are soliciting input similar to what has been gathered in the past via the CS. Stakeholders may respond to targeted questions about the clinical areas and candidate episode groups. Stakeholders may also be able to provide input on:

  • Important considerations for measure development in Wave 4
  • Preliminary measure specifications for the Wave 4 candidate episode groups
  • Clinical areas and concepts to explore for future Waves of development

Should you have any further questions, please contact the Acumen MACRA Cost Measures Support Team via email at

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