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AAMC Comments on MIPS’ Episode-Based Cost Measure Comprehensive Reevaluation

June 3, 2022

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CONTACTS
Ki Stewart, Policy and Regulatory Analyst
For Media Inquiries

The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) for revaluating and updating the eight cost measures listed below added to the Merit Incentive Payment System (MIPS) in performance year 2019.

  • Elective outpatient percutaneous coronary intervention (PCI).
  • Intracranial hemorrhage or cerebral infarction.
  • Knee arthroplasty.
  • Simple pneumonia with hospitalization.
  • ST-elevation myocardial infarction (STEMI) with PCI.
  • Screening/surveillance colonoscopy.
  • Revascularization for lower extremity chronic critical limb ischemia.
  • Routine cataract removal with intraocular lens implantation.

In the comments, the association urged the CMS to adjust cost measures for health-related social risk factors such as housing instability, low income, and health literacy, stating, “In addition to differences in patient clinical complexity, health-related social needs can drive differences in average episode costs.” The letter contended that cost measures should be adjusted to ensure physicians who treat patients with health-related social needs are accurately reflected by their score. This is particularly important for physicians at academic medical centers who often care for patients from under-resourced and underinvested communities with more complex medical needs than many patients treated elsewhere.

The AAMC also recommended that the agency establish a more clear and transparent attribution methodology to ensure the appropriate clinician is held responsible for the patient’s outcomes and costs. This attribution methodology should encourage team-based care rather than incentivize siloed care, the comments noted.  

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