As a reminder, the Centers for Medicare & Medicaid Services (CMS) and its contractor, Acumen, LLC, are gathering input on episode groups to consider for Wave 4 of the 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 Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) Wave 4 Cost Measure Development Presentation is available on the Quality Payment Program Webinar Library. This recording provides detailed information about the Wave 4 public comment approach.

The rest of this email contains more details about the public comment posting and participation. Please share this message with anyone who may be interested in providing input on the public comment posting.

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 this past year 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 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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