Physician associations are expressing mixed feelings about dramatic changes proposed for Year 3 of the Quality Payment Program (QPP) by the Centers for Medicare & Medicaid Services.
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Under its 2019 QPP proposal, CMS plans to remove 34 process-based measures within the program considered to be low value or low priority so that providers can focus more on meaningful measures that affect health outcomes, according to the agency. CMS also calls for the streamlining of the “interoperability performance category” within the Merit-Based Incentive Payment System (MIPS) to create a more simplified scoring methodology.
In regard to alternative payment models (APMs), CMS seeks to update the Advanced APM Certified EHR Technology (CEHRT) threshold so that an Advanced APM must require at least 75% of eligible clinicians in each APM entity to use CEHRT. The agency also plans to extend the 8% revenue-based nominal amount standard for Advanced APMs through performance year 2024.
Ana Maria Lopez, MD, president for the American College of Physicians said the they were pleased that CMS proposed the removal of a number of quality measures deemed to be of low value. “ACP commends CMS for taking major steps to reduce unnecessary administrative tasks that are detracting from the patient-physician relationship,” Dr. Lopez said in a statement.
But ACP officials also noted that they were disappointed that CMS did not heed calls to streamline MIPS requirements and scoring, establish a minimum 90-day reporting period for all performance categories, or reduce the total number of quality measures.
ACP supports CMS’ promoting of interoperability by requiring CEHRT, but it urged the agency to allow at least 6 months for vendors and physicians to implement system upgrades in order to ensure a smooth transition and avoid disruptions to patient care. Additionally, CMS needs to “think about ways to mitigate costs associated with implementation, especially for small practices,” Dr. Lopez said in the statement.
In an interview, Michael L. Munger, MD, president for the American Academy of Family Physicians, said that his group is reviewing the proposed QPP regulations and plans to offer its full perspective during the comment period.
“Our initial assessment indicates CMS continues progress to simplify and modernize in documentation requirements for evaluation and management office visits,” Dr. Munger said. “Reforming the U.S. health care system is an ongoing process, and the AAFP looks forward to working with CMS to ensure continued progress.”
As part of the proposed QPP changes, CMS for the first time is proposing to allow physicians to opt-in to the MIPS program if they are prepared to meet the program’s requirements. The proposal also adds a new exemption to MIPS participation: Doctors who perform 200 or fewer services under the Medicare fee schedule. The proposal retains its previous exemption thresholds for participating in MIPS – physicians who bill Medicare $90,000 or less annually and see 200 or fewer Medicare patients are excused from the program.
CMS also proposes to add new episode-based measures to the cost performance category and to create an option to use facility-based quality and cost performance measures for certain facility-based clinicians. The QPP proposal includes a number of changes for small medical practices, which include the following: