The Medical Group Management Association (MGMA), the American Medical Association (AMA), and 47 other physician organizations have sent a letter to the Centers for Medicare & Medicaid Services (CMS), calling for the federal agency to reduce the burden of the Merit-based Incentive Payment System (MIPS) by shortening the quality data reporting period from 365 to 90 days.
CMS published its calendar-year 2018 Quality Payment Program (QPP) final rule, under the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) law back in early November. Many trade associations, including MGMA, recommended at the time that CMS maintain a 90-day reporting period for the quality component of MIPS; nonetheless, in the rule, CMS increased the 2018 MIPS quality reporting period from 90 days and mandated full-year quality reporting.
In the recent letter to the federal agency, the group of associations said that the reduction of calendar year to a minimum of 90 consecutive days is necessary, “due to the lack of timely and direct notification by CMS on whether a physician is considered MIPS eligible, as well as a severe delay by CMS in updating the Quality Payment Program interactive website with 2018 information.”
They added, “It is our understanding that CMS does not plan to update the QPP website with 2018 information and measures until the summer, at the earliest. Furthermore, we request a reduced reporting period for future MIPS program years in order to reduce administrative burden and ensure physicians have sufficient time to report after receiving performance feedback from CMS.”
The letter noted that although CMS posted eligibility information on the QPP website earlier this month, the trade groups are still concerned that the late notification will impact physicians’ ability to satisfactorily participate in MIPS. The letter stated, “Several policy changes in 2018 from 2017 complicate physicians’ ability to determine their MIPS eligibility status. For example, CMS expanded the 2018 low-volume threshold exemption. While the undersigned organizations strongly support the increased low-volume threshold and believe it will assist small practices and physicians who treat a small number of Medicare patients, it may create changes in physicians’ eligibility status.”
The associations added that since they were responsible for data tracking and collection for the QPP since the start of 2018, there was a two-month lag between January and April, which is when they were finally given MIPS eligibility information. What’s more, in order to see if they are eligible for a MIPS program, physicians must actively check CMS’ website, whereas in the past they would be mailed letters. This lack of direct outreach could leave some clinicians “in the dark” regarding their eligibility status, they said.
To this end, the associations attest that the QPP website has not been updated with 2018 information and isn’t going to be updated until the summer—halfway through the 2018 reporting period. For small practices and medical group practices that manage reporting for dozens or even hundreds of clinicians under the program, the website’s educational information “is vital to the complex clinical and administrative coordination necessary to participate in MIPS,” they said.
In the end, the groups in this letter are urging CMS to alter the MIPS quality reporting period from 365 days to a minimum of 90 days. They wrote, “While we acknowledge that certain reporting options, such as reporting certain outcome-based measures, may require a lengthier reporting period than 90 days to ensure statistical validity, we believe there is a substantial opportunity to reduce the cost and labor involved in reporting MIPS data to CMS by shortening the minimum data collection period to 90 consecutive days and allowing physicians to decide whether to report additional data.” The groups added, “We also believe a minimum 90-day reporting period is consistent with CMS’ efforts to reduce clinician burden and to put patients over paperwork.”
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