- Five members of Congress encouraged CMS to lower the exclusion thresholds in the Merit-Based Incentive Payment System (MIPS) to enable more clinicians to participate in the program in a July 3 letter to CMS Administrator Seema Verma.
According to MACRA, eligible clinicians can earn adjustments of up to 7 percent on their Medicare Part B payments in 2021 based on their 2019 performance.
MACRA includes a mechanism that adjusts Part B payments based on performance measured against a threshold score. To incentivize provider participation, Congress authorized $500 million to ensure positive payment adjustments for all providers that meet the benchmark.
However, members of Congress stated current regulations reduce federal incentive payments by excluding many providers from participating in MIPS.
“For the 2018 performance year, CMS estimated that about 60 percent of otherwise eligible clinicians are excluded from MIPS,” wrote the lawmakers. “While some clinicians are not subject to MIPS requirements due to participation in Advanced Alternative Payment Models, the majority are excluded based on the current participation threshold.”
The current participation threshold lowers the maximum positive updates for Part B payment adjustments.
“For example, high performers are estimated to receive an aggregate payment adjustment in 2019 of 1.1 percent — based on their 2017 performance — even though adjustments of up to 4 percent are authorized,” wrote the members of Congress.
“This trend of continued actual adjustments that are significantly less than authorized fails to incentivize meaningful participation in MIPS,” Congress members continued. “In 2020, for example, CMS is projecting a 1.5 percent payment adjustment for high-performers, compared to a potential 5 percent adjustment level authorized under the law.”
The lawmakers further stressed that feedback from provider groups supports lowering MIPS exclusion thresholds.
“In establishing thresholds for participation in MIPS for the 2019 performance year, we urge CMS to ensure providers have a meaningful opportunity to earn a significantly higher payment adjustment, which was authorized by MACRA, up to 7 percent,” recommended members of Congress.
“We also hope CMS can incentivize more significant and meaningful participation in MIPS by adjusting low-volume thresholds adequately,” the group continued. “If MIPS does not provide meaningful incentive and opportunity for providers to be rewarded for the quality and cost of care provided, we are concerned MIPS will not fulfill its potential to improve quality and control cost.”
The American Medical Group Association (AMGA) applauded Congress members for pushing CMS to lower MIPS exclusion thresholds to enable more clinicians to participate in the program.
“As CMS develops its MIPS policies for the 2019 performance year, the agency can better tailor the program so that all providers are given the chance to succeed,” said AMGA President and CEO Jerry Penso, MD. “We understand that CMS wanted to move cautiously when implementing the MIPS program, despite the fact that it is effectively a continuation of three pay-for-performance predecessor programs.”
“Now that we are about to enter the program’s third year, it’s time to recognize that continuing to exclude a substantial percent of providers impedes moving the Medicare program to paying for value, which the Congress envisioned in overwhelmingly passing MACRA,” he continued.
The association emphasized that current low-volume threshold prevents high performers — including AMGA members — from earning the payment adjustment authorized under MACRA.
Exclusions “collapse the MIPS payment adjustment distribution curve,” the association wrote.
“CMS has an opportunity to adjust the low-volume thresholds in the regulation for 2019 so more remunerative updates are possible,” AMGA stated.
By lowering the MIPS exclusion threshold, AMGA maintained CMS will help to more effectively transition Medicare toward a value-based payment system.