- URAC, a non-profit healthcare accreditation company, recently called on CMS to implement virtual group standards under the Quality Payment Program in 2018 that promote economies of scale for more activities than just reporting compliance.
The industry group recommended that CMS support a virtual group program that allows participants to share clinical guidelines, encourage clinician responsibility, and distribute performance data among participating providers.
“When two or more practices join together, they are effectively creating a network,” Kylanne Green, URAC’s President and CEO, stated in a press release. “Collaboration shouldn’t end with compliance reporting when economies of scale and other benefits can be achieved through these alliances.”
“With the right support, CMS can create an environment where virtual groups bring together members of the medical community to promote local innovation and improved, sustainable performance,” she added.
According to the final MACRA implementation rule, no more than ten solo eligible clinicians and small practices can form a virtual group in 2018 to report to the Merit-Based Incentive Payment System (MIPS), one of the Quality Payment Program’s value-based reimbursement tracks.
In a virtual group, partnered eligible clinicians will report to MIPS and be assessed as single entity across all performance categories. The groups were designed to help solo providers and small practices to participate in MIPS.
However, CMS decided in the final MACRA implementation rule that virtual groups would not be implemented until the second Quality Payment Program performance year because of technological challenges.
In response to the CMS call for comments, URAC advised the federal agency to develop a virtual group program that can be adapted by a range of payers, not just government healthcare programs.
“If implemented with an eye toward the future, what begins as a program to meet government requirements may evolve into a commercially sustainable venture capable of delivering quality care regardless of payer,” wrote Green the letter to CMS.
To make virtual groups more commercially sustainable, URAC advised CMS to use minimum standards. Virtual group member standards should ensure that participating providers have “a mutual interest in quality, shared responsibility in decision-making, a meaningful way to effectively use their data to drive outcomes, and a mechanism to share best practices.”
CMS should also consider any opportunities to integrate behavioral health services with primary care when developing virtual group member standards, the letter added.
While URAC expressed support for some virtual group rules, the American Medical Group Association (AMGA) recently urged CMS to not develop minimum standards initially because they could inhibit how groups organize or create MIPS reporting procedures.
By not imposing minimum standards in 2018, CMS would provide more flexibility for virtual group reporting protocol development as well as promote peer-to-peer learning.
In terms of virtual group management, URAC suggested that CMS develop a platform that would allow virtual group participants to engage with each other and report to MIPS.
The primary reason CMS did not implement virtual groups in the upcoming first Quality Payment Program performance year was a lack of technology to support the program. In the final MACRA implementation rule, the federal agency stated that it found “significant barriers regarding the development of a technological infrastructure required for successful implementation and the operationalization of such provisions that would negatively impact the execution of virtual groups as a conducive option for MIPS eligible.”
Instead, CMS plans to develop a web-based virtual group registration system by 2018, using feedback from healthcare stakeholders.
URAC expressed support for a CMS-developed platform because a platform would allow interested providers to connect and partner with the most appropriate eligible clinicians.
“With technical support from CMS, groups may self-select using criteria that ensure alignment and sustainable, improved performance,” wrote Green.
The industry group also asked CMS to use quality standards developed by national accrediting organizations in virtual groups because the standards “ensure effective, shared responsibility among members focusing on improving the care delivered to patients.”
National accrediting organization-developed standards would also help protect virtual group members from potential anti-trust challenges stemming from provider consolidation.
Additionally, URAC called on CMS to disclose more information on patient-centered medical homes (PCMH) in the Quality Payment Program. CMS should publish all PCMH certification programs that will be accepted in the program.
“This public disclosure is consistent with other CMS efforts to increase transparency and will reduce uncertainty for practices,” added the letter.
URAC also argued that CMS should eliminate the requirement that certification programs accepted in the Quality Payment Program have 500 or more certified member practices. Instead, certification programs that meet national standards should be accepted.
Both virtual group and PCMH recommendations aim to support a sustainable Quality Payment Program that promotes iterative learning, URAC concluded.
“URAC stands ready to support CMS’ efforts and please feel free to call on URAC as a resource whenever we may be of assistance,” Green wrote.