- Over 100 medical organizations recently called on House Representatives to extend MACRA implementation flexibilities that allow HHS leaders to gradually implement full program requirements. The flexibilities should go on for another three years.
Through CMS, HHS extended several MACRA implementation flexibilities for the first performance year. For example, the federal department designed MACRA’s Merit-Based Payment Incentive System (MIPS) to include four performance categories: quality, cost and resource use, Advancing Care Information, and Improvement Activities.
However, CMS will not factor cost and resource use performance into MIPS composite scores for the first performance year. The federal agency explained that a flawed attribution method and inadequate quality measures contributed to their decision to gradually implement the MIPS performance category.
CMS recently proposed to extend the zero percent weight of the cost and resource category into the second performance year in 2018, rather than increasing the weight to 10 percent. The category would reach its full weight of 30 percent by the 2019 performance period.
The American Medical Association, American Academy of Family Physicians, Association of American Medical Colleges, and over 100 other organizations backed an extended implementation timeline for the MIPS cost and resource use category.
“This action in no way is meant to diminish the commitment of CMS or the physician community to incorporating resource use as an integral component of performance measurement,” the medical organizations wrote.
“It is instead an acknowledgment that work remains to be done to ensure that these new measures are developed and integrated in a way that accurately reflects the complexities of cost measurement and does not inadvertently discourage clinicians from caring for high-risk and medically complex patients, as was the case under the value-based modifier.”
Healthcare leaders also leveraged MACRA implementation flexibilities that allowed the Secretary to set performance thresholds other than the “mean or median” standard during the first two years of MIPS.
Eligible clinicians will receive MIPS payment adjustments based on performance scores that range from zero to 100. CMS plans to compare individual MIPS performance scores to a mean or median threshold.
All clinicians that exceed the benchmark will receive incentive payments, whereas all clinicians whose scores are below the median or mean standard will face penalties. The further away a performance score is from the benchmark, the greater the incentive payment or penalty.
CMS implemented a gradual increase in performance thresholds to give eligible clinicians more time to complete practice transformations and become comfortable with MIPS. For example, the performance threshold is set to 3 points in 2017, meaning reporting just one quality measure could bring eligible clinicians to the benchmark for a neutral payment adjustment.
The medical organizations encouraged policymakers to extend HHS Secretary authority to modify performance thresholds for another three years.
“Gradually increasing the performance threshold gives physicians the opportunity to implement necessary practice changes as they gain experience,” wrote the groups. “It also ensures that the performance threshold is not set too high, which could discourage participation or negatively impact practices with fewer resources.”
The MACRA implementation flexibilities are slated to expire after the program’s second year. But the medical organizations advised policymakers and HHS leaders to propose extended flexibilities in the next MACRA implementation rule, which is due by spring 2018.
Extending MACRA implementation flexibilities would make CMS “more successful in achieving Congress’s intent to focus payment systems on improving quality and value if some elements of the current flexibility provided for in statute are extended for an additional three years,” the groups explained.
Additionally, the coalition of medical organizations recommended that policymakers and healthcare leaders clarify if Medicare Part B drug and other non-Physician Fee Schedule reimbursements will be included in MIPS payment adjustment determinations.
Avalere recently reported that some specialists could face a 16 percent MIPS payment adjustment swing in 2018 if a proposal to include reimbursement for Medicare Part B drug administration is finalized.
Eligible clinicians who did not perform such services would only be subject to a 5 percent positive or negative MIPS payment adjustment.
Rheumatologists, hematologists/oncologists, and medical oncologists would be particularly affected by including Part B drug administration reimbursements.
The medical organizations also urged House Representatives to “rationalize what is considered a ‘small practice.’”
CMS proposed to award small practices of 15 or fewer clinicians five extra points to their MIPS performance scores as long as the clinicians submit data on at least one performance category. Small practices would also have a hardship exception under the Advancing Care Information category and an additional three points for measures in the quality category that do not meet data completeness requirements.
“We do not believe that these elements are being implemented in a manner consistent with Congressional intent and some technical changes in the legislative language are likely required,” the organizations concluded. “We appreciate your attention to these issues and look forward to working with you and your colleagues to ensure the implementation of MACRA continues to be successful.”