- Almost 50 provider groups are calling on CMS to reduce the Merit-Based Incentive Payment System (MIPS) reporting period from a full calendar to a minimum of 90 days during the 2018 performance year.
Among the groups advocating for increased MIPS reporting flexibilities are the American Medical Association, Medical Group Management Association, Association of American Medical Colleges, American College of Physicians, and a large number of specialty societies, such as the American Academy of Neurology, American Society of College of Surgeons, and Society of Gynecologic Oncology.
CMS should reduce the MIPS reporting period because the federal agency failed to provide timely, direct notifications of Quality Payment Program (QPP) eligibility to clinicians this year, the letter to CMS Administrator Seem Verma explained.
“While we recognize CMS posted eligibility information on the QPP website on April 6, 2018, we are concerned with physicians’ ability to satisfactorily participate in the MIPS program due to the late notification,” the groups argued. “Several policy changes in 2018 from 2017 complicate physicians’ ability to determine their MIPS eligibility status.”
The primary policy change referenced in the letter was the increase of the low-volume threshold in 2018. Under MIPS, providers who receive a low-volume of Medicare revenue or see a low-volume of Medicare patients do not have to participate in MIPS or any other MACRA programs.
CMS updated the low-volume threshold for the 2018 performance period to support small practices with MIPS participation. The low-volume threshold increased from $30,000 or less in Medicare Part B allowable charges to $90,000 or less in Physician Fee Schedule services performed on Medicare Part B fee-for-service beneficiaries.
The low-volume threshold for patient volume also increased from 100 or fewer Part B-enrolled Medicare beneficiaries to 200 or fewer Medicare Part B fee-for-service beneficiaries.
In addition, the Bipartisan Budget Act of 2018 changed QPP eligibility policies. The act excluded Medicare Part B drug costs from MIPS payment adjustments and the low-volume threshold determinations.
“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 provider groups contended.
In light of the recent changes, providers could no longer rely on historical data to determine if they were eligible to participate in the QPP even though they were responsible for collecting data as of Jan. 1, 2018, if they were eligible.
Furthermore, by the time CMS had QPP eligibility information available, providers had to actively go to the CMS website to check their eligibility. The federal agency did not mail QPP eligibility letters to providers as it has done in the past with legacy value-based purchasing programs.
“Without direct outreach by CMS to physicians and group practices, many physicians will be left in the dark on their status,” the groups wrote.
CMS should also reduce the MIPS reporting period in 2018 because the federal agency has yet to update the QPP website with information on the 2018 performance period, the groups argued.
“It is our understanding that CMS does not plan to update the website until the summer, at the earliest, which is halfway through the reporting period,” they explained. “Given the QPP website is the primary means for educating physicians on the program, this severe delay would undermine physicians’ ability to meet the 2018 requirements to successfully avoid a penalty.”
A 90-day MIPS reporting period should be enough to capture care quality as evident from the reduce reporting period in 2017. the groups added.
“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,” they wrote.
In the final rule on 2018 MACRA implementation, CMS estimated the burden of data collection and submission to the QPP to total 7.6 million hours with a cost of almost $700 million this year.
But the CMS estimate could be on the low side, according to a 2016 Health Affairs study that found practices spend 785 hours per physician, on average, and over $15.4 billion total on quality measure reporting.
The reduced MIPS reporting period would also align with the federal agency’s push to decrease clinical burden and prioritize patients over paperwork. The Patients Over Paperwork initiative from CMS created an internal process to assess and streamline regulations with a goal to decrease unnecessary burden, increase efficiencies, and improve the beneficiary experience.
A 90-day MIPS reporting period would advance the initiative because full-year reporting reduces clinician burden.
“Our organizations are committed to working collaboratively with CMS to ensure MIPS recognizes the quality of care provided to Medicare beneficiaries rather than quantity of data reported,” the groups concluded. “We appreciate your consideration of our recommendation to reduce the onerous MIPS documentation requirements by shortening the quality reporting period to a minimum of 90 days.”