Healthmonix Advisor

How to Comment on the 2019 Proposed Rule

Posted by Christopher Jayne on July 27, 2018
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The Centers for Medicare & Medicaid Services (CMS) released the 2019 Proposed Rule for the Medicare Physician Fee Schedule on July 12, 2018. The release of the 2019 proposed rule is advantageous in deciding what to conquer under the Quality Payment Program for both this year and in the future, which is why we published a series of posts summarizing the major proposed changes you should be aware of. But what if you have a suggestion that would improve the rule?

The good news is that these changes aren’t yet set in stone. CMS is accepting feedback until the deadline of September 10, 2018, and will respond to comments and make any changes in the final rule.

In past years, comments submitted during this period have affected the rule in significant ways. In 2018, for example, the proposed rule would not have allowed for the use of 2014 CEHRT, but this was changed for the final rule based on the feedback CMS received. So if you have a suggestion or comment, it may be well worth your time to submit.

Even if the comments do not lead to immediate changes, you still get to view the rationale behind CMS decisions and view the narrative surrounding this program.  This gives you a good preview of potential changes coming in 2020 or beyond. The proposed rule also has a section dedicated to retired or added measures proposed, which concretely affects your ability to report and receive the highest score. In a way, engaging the proposed rule is the best first step in 2019 reporting.

We recommend sharing this information with anyone you know who is affected by MIPS.  Your peers are a great start, but consider forwarding information to your specialty society or professional organizations as well, to make sure your voice is amplified and heard.


How to submit comments

Instructions for submitting comments can be found in the proposed rule itself, which can be downloaded from the Federal Register here. You must submit comments in one of the following official ways:

  • Electronically through
  • Regular mail
  • Express or overnight mail
  • Hand or courier

Please note that CMS will NOT accept FAX transmissions.

If you would like more information about the proposed rule or the Quality Payment Program in general, go to To contact the QPP directly, you may call 1-866-288-8292 (TTY 1-877-715- 6222) Monday through Friday, from 8:00 AM-8:00 PM Eastern time, or reach them by email at


Topics: PRO Tips, MACRA & MIPS