The AAMC Nov. 17 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS)’s request for information (RFI) regarding implementation of the Merit-based Incentive Payment System (MIPS), Promotion of Alternative Payment Models (APMs), and Incentive Payments for Participation in Eligible Alternative Payment Models.
The RFI was an opportunity for stakeholders to provide feedback regarding this transition prior to Jan. 1, 2019, when physician payments will be driven by either transitioning to APM or participating in MIPS, a consolidated pay-for-performance program.
The AAMC raises a number of major points in its comments, including: encouraging physician-hospital collaboration to allow many physicians to participate and be successful; ensuring appropriate risk adjustments to avoid disadvantaging physicians who care for the most complex and vulnerable patients; and recognizing that much of the routine work done by teaching physicians constitute clinical practice improvement activities under MIPS.
The MIPS composite score will be weighted on four categories: quality performance, resource use, meaningful use, and the clinical practice improvement activities (CPIA). As CMS considers the framework for MIPS, the AAMC requests minimal changes to the current physician quality programs to allow physicians to smoothly integrate changes into their daily workflow and avoid overly burdensome reporting requirements.
The AAMC also recommends that CMS allow multiple options for identifying providers to assess eligibility, participation, and performance under the MIPS program, including creating a MIPS identification option for multispecialty groups. Additionally, the AAMC encourages CMS to recognize that much of the work already done by teaching physicians, such as training medical students and residents and participating in research, should meet the requirements of the CPIA category.
While the Medicare Access and CHIP Reauthorization Act (MACRA, P.L. 114-40) creates strong incentives for rapid adoption of APMs, the AAMC requests that CMS implement flexible requirements around the classification of qualified APM participants and adopt measures that create a reasonable tiered approach in managing increasing levels of financial risks.
The AAMC also encourages CMS to consider all organizations with any down-side risk, required savings or discounts, or significant up-front investment to be considered as an eligible APM. Finally, the AAMC requests that CMS allow for maximum flexibility in how quality is measured for APMs and that CMS should be broad in defining eligible APM measures “comparable” to MIPS’ measures, as required by the statute.
CMS will publish the proposed rule regarding MIPS and APMs in the spring of 2016 and the final rule is expected to be released in November 2016.