The Alliance of Specialty Medicine has said it opposes the Medicare Payment Advisory Commission’s (MedPAC’s) recent suggestion to repeal MIPS (the Merit-based Incentive Payment System) in its current form.
The coalition of specialty societies, which represents more than 100,000 specialty physicians from 13 specialty and subspecialty societies, wrote a letter to MedPAC’s Chairman Francis J. Crosson, M.D., responding to MedPAC’s October meeting in which the Congressional agency came to near-unanimous agreement that MIPS should be scrapped.
MACRA’s (the Medicare Access and CHIP Reauthorization Act) Quality Payment program is inclusive of two payment paths that eligible Medicare-participating physicians could partake in—MIPS and the advanced alternative payment model (APM) track—and began in January 2017.
According to a story in MedPage Today, MedPAC analysts have discussed an alternative policy approach that leverages population-based measures. As the MedPage report noted, “The Voluntary Value Program, as they've dubbed the alternative, would get rid of the MIPS program and all three types of reporting requirements—Advancing Care Information (ACI), Clinical Practice Improvement Activities (CPIA), and quality measures—and scrap CMS support for electronic health records [EHRs] reporting.”
In this new model, all clinicians would see a portion of their fee schedule dollars withheld, which would be lumped into a pool. Clinicians would then have three options: choose to be measured with a "sufficiently large entity" of clinicians and be eligible for value payments; choose to participate in an advanced APM model (and receive withhold back); or make no election and lose the withheld fee schedule dollars.
During the October meeting, almost all MedPAC members said they are in favor of a MIPS repeal.
But the specialty societies are in major disagreement with MedPAC. They wrote that they strongly oppose this policy option and recommendation for several reasons: first, a lack of A-APMs for specialists to meaning fully engage exists; second, the limitations of population-based measures in determining quality and cost of specialty medical care will hinder specialists’ performance in “large” entities; third, MACRA very clearly intended to promote the development of clinically relevant, specialty-based quality measures; fourth, most physicians do not practice in “large” entities; thus impeding these individuals or groups from successful participation; and finally, fee-for-service remains a viable reimbursement structure for many specialists and subspecialists where alternative models of care and payment have already addressed the value equation for the vast majority of their services.
The Alliance specifically references a Leavitt Partners report which said that not every provider has a path forward under the A-APM track of the QPP, and some specialty providers have no opportunity to be in that track at all. The letter noted, “Specialists, such as ophthalmologists, neurosurgeons, and rheumatologists, will see 153 (0.7 percent), 46 (0.8 percent) and 79 (1.4 percent) of their respective specialty physicians in Medicare qualify for an incentive under the APM track, whereas the remaining will participate in the MIPS program.”
As such, the letter concluded, “Eliminating MIPS in favor of MedPAC’s proposed new quality program would discourage specialty physicians from developing robust quality and outcomes measures, including the establishment of high-value clinical data registries, and would thwart efforts to collect and report performance data.”
It should be noted that according to that MedPage report, not all MedPAC members supported the new model despite favoring a MIPS repeal. One member said that since it’s voluntary, providers can always choose to go back to traditional fee-for-service, which would not be beneficial. Another member pondered if the proposed model was too close to the advanced-APM structure.
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