- The American Hospital Association (AHA) has submitted a list of policy proposals to the Medicare Payment Advisory Commission (MedPAC) regarding implementing the Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs) and other provisions of MACRA.
In the letter, AHA Executive Vice President Thomas P. Nickels emphasized the importance of drawing upon data and experience from healthcare organizations before proposing any policy changes to MACRA.
Because clinicians are still acclimating to MACRA policy requirements and the transition year of the Quality Payment Program, no data currently exists that assesses the effectiveness of policies in place.
“The first performance period for the MIPS and APMs began on Jan. 1, 2017 – less than two months ago. As a result, clinicians and hospitals with whom they partner are at the very beginning of putting the MACRA’s policy requirements into action,” wrote Nickels.
As a result, AHA suggested the commission hold off on restructuring MACRA implementation until there is information available to inform significant changes.
AHA also advised the commission on potential changes to its policies for MIPS participation.
“Rather than assigning clinicians to groups or regions, we believe the Commission should focus on policy approaches that expand the options for clinicians to voluntarily collaborate with others on quality and cost,” Nickels recommended. “Specifically, we strongly support the implementation of a MIPS participation option that allows for hospital-based physicians to use their hospital’s CMS quality and resource use measure performance in the MIPS.”
AHA maintained allowing providers to collaborate in this way supports alignment of quality improvement efforts across the care continuum, encouraging standardization across the industry. The association also supported the concept of clinicians retaining the freedom to join together voluntarily instead of being lumped together by region automatically.
Additionally, AHA petitioned MedPAC to shift the focus of MIPS measures for evaluating provider performance in this portion of the Quality Payment Program.
Along the lines of ensuring CMS evaluates clinicians based on accurate reporting measures, AHA urged the commission to avoid using claims data as the primary reference point for assessing provider performance:
The AHA also is concerned by the Commission’s proposal to replace most clinician reported measures with outcomes measures calculated by CMS. We appreciate that MedPAC recognizes the significant resources required to collect and submit quality data. However, most measures calculated by CMS would be based on Medicare claims data. While claims data have a role in quality measurement, they cannot and do not fully reflect the details of a patient’s history, course of care and clinical risk factors. Such information is crucial to performing the risk adjustment that most outcome measures require to fairly compare provider performance. As a result, many claims-derived outcome measures do not accurately reflect provider performance. Basing clinician performance on unreliable data would be highly problematic.
Cost is a major concern for AHA as MACRA implementation potentially brings with it significant financial burden on hospitals and clinicians. According to the association, the financial implications of MACRA implementation are perhaps too steep and potentially punishing for providers.
AHA stated its opposition to the requirement that clinicians participating in advanced alternative payment models (APMs) should receive only a five percent alternative payment model (APM) incentives if they fulfill the objectives this Quality Payment Program pathway, since APMs are meant to “encourage participation in advanced APMs, not reward or penalize performance.”
The diminished incentive is insufficient considering the burden of implementing the APM itself, AHA claimed. Because the cost of developing infrastructure in order to enter into new payment models is financially demanding, AHA suggested CMS expand its definition for determining financial risk and include the risk of investments providers make to participate in APMs in the first place.
The association’s concluding request for the commission is to avoid altering MIPS in a way that adversely affects small practices.
With these suggestions, AHA hopes to smooth the transition to the Quality Payment Program and MACRA implementation for providers and ensure the transition to value-based care has a positive effect on patient care and EHR use instead of imposing additional regulatory and financial burden on participating practices.