- In a recent letter to CMS Acting Administrator Andy Slavitt and Director of the Office of Management and Budget Shaun Donovan, the GOP Congressional Doctors Caucus called for several MACRA implementation changes to make the value-based reimbursement program less burdensome on providers.
The group of 18 House representatives specifically urged CMS to simplify the Merit-Based Payment Incentive System (MIPS) by providing eligible clinicians with regular feedback, shortening reporting periods, implementing virtual groups, establishing more attainable MIPS exclusion thresholds, and delaying resource use scoring.
“In order to be successful, MIPS must engage clinicians with a reporting system that is not overly burdensome, a scoring system that is simple and transparent, attainable thresholds, and a short enough quality/payment feedback loop to allow physicians to learn and make necessary changes to avoid further penalty,” the caucus wrote.
Under MIPS, eligible clinicians would be required to monitor and report on at least 22 measures, including a minimum of eight measures on quality, two measures on resource use, 11 measures on Advancing Care Information, and two measures on clinical practice improvement activities.
With so many measures required, the caucus advised CMS to provide clinicians with regular, detailed feedback to help participants better understand their performance scores, including causes for penalty assessments, reporting rates for each measure, scoring methodology, and mistakes in received data.
“A transparent process with detailed reports will aid providers to more quickly rectify inaccuracies in their data, and enhance their ability to submit timely appeals before payment reductions are applied and performance ratings are made public,” the letter stated. “In the past, eligible professionals were left to decipher this rationale on their own, taking valuable time and resources away from patient care.”
Additionally, the caucus called for shorter MIPS reporting periods to ensure all eligible clinicians have an equal opportunity to succeed under the value-based reimbursement program. CMS proposed to establish year-long MIPS reporting periods, but the caucus advised the federal agency to adopt a 90-day timeframe.
“Especially in the initial years of MIPS, a shorter reporting period is necessary for all providers, but particularly smaller practices who have fewer resources to keep up with the changing regulatory environment,” wrote the caucus. “A shorter reporting period would ensure that more providers are able to successfully make the transition to MIPS, upgrade their EHR technology and meet the new Stage 3 measures by 2018.”
CMS should also lower patient minimum reporting thresholds to better support small and rural practices, the caucus stated. The federal agency proposed that providers who use a registry would report quality measures on 90 percent of their patients from all payers, including 80 percent of Medicare patients for those reporting by claims.
However, the caucus suggested that CMS lower the minimum threshold to a maximum of 50 percent of Medicare patients to ease administrative burden and make quality reporting more flexible.
The House representatives also urged CMS to make virtual groups readily available to eligible clinicians before the proposed 2018 performance period. Under MIPS, clinicians in the second year can elect to be assessed as a group for all four performance categories and receive a combined MIPS score.
Virtual groups, the caucus stated, should be formed as soon as possible to make sure the scoring option is widely communicated to eligible clinicians and interested providers have enough time to organize and participate. The groups would be a key resource for small practices trying to develop workflows and infrastructure needed to succeed under MIPS.
CMS should develop more attainable MIPS exclusion thresholds, the caucus added. The proposed MACRA implementation rule stated that practices with less than $10,000 in Medicare allowed charges and fewer than 100 unique Medicare patients per year would be exempt from MIPS participation.
A recent American Medical Association report, however, found that only 10 percent of physicians and 16 percent of all MIPS eligible clinicians would qualify for exclusion under the proposed thresholds. The clinicians represent less than one percent of Medicare allowed charges for Physician Fee Schedule services.
The House representatives recommended that CMS change the exclusion threshold to $30,000 in Medicare allowed charges or fewer than 100 unique Medicare patients per year. The broader threshold would establish a better safety net for small practices while still ensuring most providers are participating in MACRA.
“This would exclude less than 30 percent of physicians while still subjecting more than 93 percent of allowed spending to MIPS,” stated the letter.
In addition, the caucus advised CMS to delay the implementation of the resource use performance category for at least one year. Most of the resource use measures were developed for hospitals in the Value-Based Modifier program, meaning the measures are “neither accurate nor relevant for many physicians.”
MACRA also mandated CMS to develop new episode measures and physician-patient relationship codes to ensure accuracy and reliability of resource use scores. But final codes don’t need to be completed until 2018, a year after MACRA’s launch, and episodes measures have yet to be tested for physician use.
Therefore, the caucus urged CMS to delay resource use scoring until the measures and scoring methodologies have been reviewed.
A final MACRA implementation rule is expected to be released sometime before November 1.