The AAMC Aug. 21 submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding proposed 2018 updates to the Medicare Quality Payment Program, which was created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, P.L. 114-40). The AAMC encourages CMS to use the flexibility provided under the Quality Payment Program to create a longer transition period, with the goal of reducing complexity and provider burden.
In addition, the AAMC offered focused comments on the following areas related to the Merit Improvement Based Incentive System (MIPS) and Alternative Payment Models (APM) options:
- Risk Adjustment: As appropriate, risk adjust outcome, population based measures, and cost measures for clinical complexity and sociodemographic factors.
- MIPS Identifiers: In addition to using the tax identification numbers (TINs), national provider identifiers (NPIs), APM Identifiers, and virtual group identifiers, CMS should create an option for a MIPS subgroup identifier that would allow large multi-specialty groups to elect to have sub-groups under the same TIN assessed in the quality payment programs in a meaningful way.
- Quality Category: Continue to allow 90 days for reporting the quality performance category to allow additional time for clinicians to implement the quality measures in their practices and to understand the scoring method.
- Cost Category: Maintain the weight of zero percent for 2018 performance year. Address risk adjustment and attribution concerns prior to implementation of the cost category.
- Improvement Activities: Finalize the new improvement activities related to teaching, research, and continuing medical education and consider further expansion.
- Advancing Care Information: Finalize the proposal to allow the use of 2014 edition certified electronic health records technology (CEHRT) past 2017 and clarify the scoring methodology.
- Assessment Dates for APM Participation: Finalize the fourth assessment date of Dec. 31, as it allows an eligible clinician who joins later in the year to be scored under the APM scoring standard. CMS should also expand the end of year date more broadly to include all MIPS APMs and Advanced APMs.
- Nominal Financial Risk Definition: Do not increase the financial threshold in future years and eliminate the 50 clinician cap on medical homes.
- Qualifying Participant Threshold: Make it more feasible to achieve the qualifying APM thresholds by limiting the threshold calculations to those beneficiaries that live within the APM entity’s primary service area.
- Other Payer Determination: Instead of requiring that eligible clinicians submit information for other APM determinations, the AAMC recommends that CMS require the payers to submit this information to CMS about their models for approval.
- Medicare Threshold for Advanced APMs: CMS should consider reducing the Medicare threshold in the future to enable participants in these models to continue to qualify to receive the five percent bonus.
CMS will issue a final rule by Nov. 1, 2017 with an effective date of Jan. 1, 2018.