Society Urges Stability, Flexibility in Response to Physician Quality Payment Program Rule

August 25, 2017

This week, the Society submitted a response to the Quality Payment Program (QPP) proposed rule the Centers for Medicare & Medicaid Services (CMS) issued earlier this summer. The rule, which addressed both the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) continued the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) law and was the first rule to signal the direction of the new Administration. In its response, the Society urged CMS to establish a period of stability in the program so that physician practices can prepare and get used to participating in the program. “As this program continues to be implemented, physician practices need time to transition their practices to meet these requirements. Unfortunately, that has been very difficult given the constant changes in many of the program requirements. Starting with the legacy programs, the number of measures, minimum patient thresholds, and many other details of the program have continued to change year to year. That does not allow for practices to build a sound strategy as they seek to implement changes in their practice,” stated the letter. Likewise, the Society argued that constant changes in the program did not allow CMS to provide meaningful feedback to practices that are trying to transition into valued-based medicine and quality reporting programs.

The Society praised CMS for its willingness to treat the second year of the program as another transition year and urged CMS to be as flexible as possible. The Society argued that stringent reporting requirements only push practices to report on measures that are at best not applicable or at worst not good for patient care. The Society pointed to the current requirement to report at least one outcome measure that has forced practices to report on measures that are not good for patient care. The Society continues to work with CMS and other stakeholders on measure development and hopes to develop measures that are more meaningful for PA/LTC clinicians and their patients. Given the resources and time necessary for these projects, the Society urged CMS to be flexible in its approach and ensure that quality payment programs do not dis-incentivize practitioners from PA/LTC medicine.

With that in mind, the letter applauded CMS for proposing not to apply cost measures of physician practices for the second year of the program. These measures putpractices with high risk/complex and costly patients at a disadvantage. Instead, the Society supported proposals for providing bonus points for clinicians who see these types of patients and urged the agency to address the long-standing issue of appropriate risk adjustment in quality measurement. “Without proper risk adjustment in the program, clinicians who see complex patients in PA/LTC settings will continue to be disadvantaged, which flies in the face of goals of the entire program,” stated the letter. In addition to supporting proposals for Hierarchical Condition Category (HCC) and dual eligibility adjusters, the Society urged CMS to look at place of service to provide further granularity in complexity of clinicians’ patient population.

The Society also urged flexibility in applying different weights to categories within the MIPS reporting program. Specifically, the letter asked that CMS apply more points to the Improvement Activities (IA) category given the proposed added activities that align with clinicians’ work in post-acute and long-term care (PA/LTC). The Society supported proposals to include two new activities: physician participation in the Partnership to Improve Dementia Care and physician participation in the Quality Assurance and Performance Improvement (QAPI) process. Applying more weight to this category would bring balance to the program and mitigate the issues about risk adjustment and benchmarking in the quality category.

The Society urged CMS to work together to provide more education and details about getting credit for participating in these projects.

Finally, the Society urged CMS to provide more pathways for PA/LTC clinician participation in alternative payment models (APMs). CMS did not propose any changes or add new APMs in this proposed rule. Current models, such as the Comprehensive Primary Care Plus, could be expanded to address the PA/LTC population and provide gain-sharing opportunities for PA/LTC argued the letter.

To read the full letter please click here.