- Continuing the small practice bonus, but including it in the quality performance category score of clinicians in small practices instead of as a standalone bonus.
- Awarding small practices three points for quality measures that don’t meet the data completeness requirements.
- Consolidating the low-volume threshold determination periods with the determination period for identifying a small practice.
David Daikh, MD, president for the American College of Rheumatology, said the ACR appreciates CMS’ emphasis on supporting the development of alternative payment models (APMs) and is encouraged by the agency’s proposal to allow more physicians to participate.
“However, we are concerned that eliminating the MIPS small practice bonus as a stand-alone bonus and instead folding it into the quality performance score would dilute the bonus and hurt small and rural providers,” Dr. Daikh said in a statement. “The ACR strongly supports maintaining the small practice bonus as a five-point stand-alone bonus that is added to the final score.”
Meanwhile, Jerry Penso, MD, president and CEO for the American Medical Group Association expressed disappointment that CMS did not lower its exclusion threshold for MIPS. Through the Bipartisan Budget Act of 2018, CMS plans to continue “the gradual implementation of certain MIPS requirements to ease administrative burden on clinicians,” according to a CMS fact sheet. This includes flexible performance thresholds until the fifth year of the QPP. The agency previously required the MIPS cost performance category to have a weight of 30% in Year 3 of the program (performance period 2019); however, the weight is now required to be no less than 10% and no more than 30% for the third, fourth and fifth years of the QPP.
Dr. Penso noted that as authorized by the Medicare Access and CHIP Reauthorization Act (MACRA), providers were given the opportunity to earn an adjustment of up to 7% on their Medicare Part B payments in 2021 based on their 2019 performance.
“However, as indicated in [the] proposal, CMS estimates the overall payment adjustment will be 2%,” Dr. Penso said in a statement. “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.”
Some specialty associations, including the American Academy of Dermatology, said they are still reviewing the proposed policies and could not comment on the changes at this time.
“The American Academy of Dermatology is still looking at the proposed rule and the implications it may have on board-certified dermatologists and their patients,” an association spokesperson said in an interview.
Comments on the proposed rule will be accepted at www.regulations.gov until Sept. 10.