- CMS recently proposed several changes to Medicare physician payments and MACRA’s Quality Payment Program to reduce medical billing and administrative burden. But initial reactions from medical group associations have not been positive.
AMGA, formerly the American Medical Group Association, stated that proposed changes are a “missed opportunity to move Medicare provider payments to value.”
Specifically, the medical group association took issue with the federal agency’s proposal to continue reporting flexibilities for the Quality Payment Program’s third year. If finalized, the performance threshold in 2019 for the quality program’s Merit-Based Incentive Payment System (MIPS) would be just 30 points.
CMS also intends to use the authority granted to them by the Bipartisan Budget Act of 2018 to establish flexible performance thresholds until the fifth year of the Quality Payment Program. In a fact sheet on the proposal, the federal agency stated that it wants to “ensure a gradual and incremental transition to the estimated performance threshold for the sixth year of the program based on the mean or median of final scores from a prior period.”
The federal agency also veered away from the final MACRA implementation plan by lowering the weight of the MIPS Cost category. According to the original plan, the performance category is supposed to have a weight of 30 percent in the third year of the Quality Payment Program.
However, CMS proposed to gradually introduce the Cost category because it is new to clinicians. Unlike other MIPS performance categories, the Cost category did not replace legacy Medicare programs.
For 2019, the performance category would carry a weigh not less than 10 percent, but not more than 30 percent for the third, fourth, and fifth years of the Quality Payment Program.
AMGA expressed disappointment with the gradual implementation of the Quality Payment Program because it unfairly penalizes providers who already made investments and prepared for full MACRA implementation.
Eligible clinicians will now only be able to earn overall payment adjustments of 2 percent of their Medicare Part B payments based on their 2019 performance, whereas they would qualify for 7 percent payment adjustments if CMS implemented MACRA as originally intended.
“AMGA members will continue to work to provide superior quality care to their patients,” said Jerry Penso, MD, MBA, AMGA’s President and CEO. “We are concerned that CMS has again opted not to recognize the efforts of high-performing AMGA members. As we enter the program’s third year, it is time for CMS to honor congressional intent and use MIPS to create value for Medicare.”
The Medical Group Management Association (MGMA) also voiced discontentment with proposed MIPS policies.
The industry group argued that the proposed 365-day MIPS quality reporting period for the Quality and Cost performance categories does not reduce administrative burden.
“MGMA is disappointed that CMS plans to continue its burdensome 365-day MIPS quality reporting policy rather than 90 consecutive days,” the group’s Senior Vice President of Government Affairs Anders Gilberg said in an emailed statement.
“Reducing the reporting burden would allow more physicians to participate in MIPS and focus the program on rewarding quality care rather than quality reporting. Requiring medical groups to submit excessive amounts of data to the government has little impact on the quality of care delivered to Medicare beneficiaries.”
The medical group association also argued that proposed EHR requirements would do little to decrease administrative burdens.
CMS proposed to require eligible clinicians to use 2015 Edition Certified EHR technology in the third year of the Quality Payment Program. Clinicians only needed the 2014 or 2015 editions to earn points under the MIPS performance category in the past.
“Today’s rule proposes to require physicians to deploy costly EHR upgrades for 2019 and takes further steps toward implementing burdensome appropriate use criteria,” Gilberg stated. “At first glance, the rule doesn’t meet MGMA’s definition of administrative simplification.”
While medical group advocates criticized the proposed Quality Payment Program changes, the American Hospital Association (AHA) commended CMS.
“We applaud CMS for taking action to reduce the regulatory burden hospitals and health systems face, including advancing their ‘Meaningful Measures’ initiative,” wrote Tom Nickels, AHA’s Executive Vice President. “This also includes better aligning the Promoting Interoperability Performance Category in the Quality Payment Program with the interoperability program proposed for hospitals in the inpatient rule.”
The hospital industry group also praised proposed updates to Medicare’s telehealth coverage. Changes to the Medicare Physician Fee Schedule would pay providers for more telehealth and virtual care, such as virtual check-ins and evaluations of patient-submitted photos.
However, the AHA expressed concerns with other potential changes to the Medicare Physician Fee Schedule, including site-neutral payment policies.
In the proposed fee schedule rule, CMS stated that it intends to continue exploring alternative reimbursement models for off-campus hospital outpatient departments. The off-campus facilities would be paid under an adjusted Physician Fee Schedule rate.
“[W]e remain disappointed that CMS continues its short-sighted policies on the relocation of existing off-campus hospital outpatient departments. These ‘site-neutral’ policies ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients and communities,” Nickels wrote.
“We also continue to urge CMS to improve its payment methodology to better account for the fact that the outpatient payment system includes many more services in its payment rates than the PFS [Physician Fee Schedule].”
The AHA also criticized potential drug reimbursement reductions and evaluation and management category restructuring. The group specifically warned that the latter would provide “substantially less ability to distinguish evaluation and management codes for different levels of resource use and intensity of services means that physicians who provide care for a disproportionate number of high-acuity patients would consistently, and unfairly, receive underpayment,” Nickels stated.
Healthcare stakeholders have until Sept. 10, 2018, to submit formal comments to CMS on the proposed changes to both the Medicare Physician Fee Schedule and the Quality Payment Program.