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.