The American Hospital Association (AHA) suggested the Medicare Payment Advisory Commission (MedPAC) refrain from pushing for major changes to the Merit-Based Incentive Payment System (MIPS) to avoid further confusing providers still adjusting to the fledgling program.
The association urged MedPAC to hold off on advocating for MIPS policy changes in a recent letter, one which also included recommendations about improving incentives and ensuring equity of payments for different care settings.
AHA clarified that its members support the commission’s interest in identifying ways to improve MIPS requirements and the federal program of which it is a part — the Quality Payment Program (QPP). However, the organization stated that the newness of the program requires that providers have sufficient time to adjust to the current program before policies are changed, eliminated, or introduced.
“Changing course on the MIPS so soon after program implementation could lead to confusion in the field, and prompt clinicians to spend time deciphering the requirements of a new program rather than on improving care,” the AHA letter stated.
Additionally, the letter question the availability of reliable data or experience that MedPAC and other stakeholders would need in order to support significant policy changes.
MedPAC’s policy change entails scrapping MIPS and replacing it with the Voluntary Value Program (VVP). VVP builds on the suggestions MedPAC submitted to Congress in its 2017 June report.
The commission stated MIPS places significant burden on clinicians, includes extremely complex requirements, and lacks a compelling association with high-value care. The new program would differentiate between high and low performing practices and utilize population-based measures. Additionally, clinicians could elect to be measured with a large entity of clinicians and be eligible for a value payment.
AHA did express support for the commission’s proposal seeking to avoid assigning clinicians to groups in their communities and instead allowing clinicians to choose their own groups.
“The AHA has always supported the notion of clinicians coming together voluntarily to participate in the MIPS as a group practice, as it provides a way to share resources and improvement strategies,” wrote AMA. “Allowing clinicians to form their own groups is appropriate given the considerable variation in market composition and the ability of clinicians to collaborate on improving performance.”
However, AHA discouraged MedPAC from advocating for claims data to take the place of quality data. The association cautioned MedPAC against pushing for a value-based care incentive program that relies too heavily on claims-based measures.
“We appreciate that MedPAC recognizes the significant resources required to collect and submit quality data,” stated the association. “Without question, using Medicare claims entails less data collection effort on the part of clinicians. However, claims data cannot and do not fully reflect the details of a patient’s history, course of care and clinical risk factors.”
Information about patient medical history, treatment, and clinical risk factors are necessary to perform risk adjustments required to fairly compare provider performance for most outcomes-based measures.
“As a result, many claims-derived outcome measures do not accurately reflect provider performance,” wrote AHA. “Basing clinician performance on unreliable data would be highly problematic.”
Regardless of whether policymakers show an interest in following MedPAC’s recommendation to replace MIPS with VVP, the program is still subject to frequent modification.
The most recent policy changes to MIPS came in early November when CMS released the QPP 2018 final rule. The final rule includes tailored flexibilities for small practices of 15 or fewer clinicians. The second year of QPP will also include flexibilities that resemble the transition year to help clinicians prepare for the program’s third year.
Stakeholders including the National Committee for Quality Assurance (NCQA) and the American College of Physicians (ACP) have voiced support for the final rule.