- Atop its voluminous list of recommendations for the Quality Payment Program, the American Medical Association (AMA) has advised CMS to simplify the scoring of physician performance in Merit-based Incentive Payment System (MIPS).
In a letter to Administrator Seema Verma on Monday, AMA CEO & Executive Vice President James L. Madara, MD, urged the federal agency to make simplicity the goal of this part of the Quality Payment Program.
“A goal that should be set throughout the MIPS program is to create stable requirements that do not change from year to year. This is the easiest way to ensure participants can learn about and prepare for the MIPS requirements,” he wrote.
“Accordingly, we urge CMS to avoid changes or short-term policies that disrupt understanding of the program,” he continued. “If such changes are necessary, they should generally be made in a fashion that protects participants as opposed to placing more individuals at risk for a financial penalty.”
To build familiarity with and encourage participating in MIPS, the organization also urged CMS against setting the bar too high physicians and practices getting starting in the program:
The AMA was extremely supportive of the pick-your-pace approach CMS adopted for the first performance year and the decision to set the performance threshold at three. This provided physicians with an opportunity to learn the MIPS program and adopt practices that will help them to successfully participate in the future. We believe that CMS should maintain its transitional year policies and continue to set the performance threshold at an achievable level for all participants as they gain experience with the MIPS program. We therefore urge CMS to set the performance threshold for the second program year at six points.
AMA offered two reasons for setting the low performance threshold at six points.
First, this MIPS scoring change would reduce the likelihood of penalties being assessed to participants and increase participation in this part of the Quality Payment Program without sacrificing progress.
“By setting the threshold at six, CMS is moving the needle of MIPS performance forward without discouraging physicians or creating a bar that is unachievable, especially for small practices and new participants,” the letter stated.
Second, the organization claimed a low performance threshold would help participants become comfortable with MIPS requirements.
“MIPS participants are still learning the program and will only have had one year of experience with the different categories, scoring methodology, timelines, and other requirements,” Madara maintained. “Gradually increasing the threshold for the second performance year ensures that participants can continue to gain familiarity with the program and can work to restructure their practices to prepare for future MIPS reporting.”
In keeping with previous criticism of the EHR Incentive Programs, AMA noted the need for CMS to share data about participant performance in MIPS thus far as a means of ensuring the program scales up fairly:
CMS could then use the 2017 data to set subsequent MIPS performance thresholds, which could avoid a steep jump for future program years. We, however, urge CMS to share with us additional information and data that it may have to understand how it will establish future performance thresholds and the differences in selecting the mean vs. the median. We continue to believe that our estimates are very different from those in the proposed rule and are concerned that these disparities could drive policy decisions that create significant challenges for physicians.
This line of reasoning also holds true for the organization’s recommendations for 2019 MIPS scoring, which AMA called to be based on data and analysis of previous MIPS performance thresholds.
Also on the subject of MIPS scoring, the organization advised CMS to eliminate variability in weighting bonus points, avoid factoring bonus points into its methodology for setting future performance thresholds, and increase the reliability threshold for cost or quality measures.