- Forty-four medical associations, groups, and societies recently issued a letter to CMS urging the federal agency to reduce the 2018 Merit-Based Incentive Payment System (MIPS) quality reporting period from a calendar year to a minimum of 90 days for reduced administrative burden.
Associations including AMA, the American Academy of Family Physicians, (AAFP), the American College of Gastroenterology, the American College of Physicians, and others recommended CMS reduce the MIPS reporting period to 90 days due to the federal agency’s failure to inform physicians of their MIPS eligibility status in a timely manner.
Groups also cited CMS’ delay in updating the Quality Payment Program (QPP) interactive website with information pertaining to 2018 MIPS as another reason to reduce the reporting period window.
“Furthermore, we request a reduced reporting period for future MIPS program years in order to reduce administrative burden and ensure physicians have sufficient time to report after receiving performance feedback from CMS,” wrote physicians.
CMS posted MIPS eligibility information for physicians to the QPP website on April 6, 2018. Because of the significant number of new policy changes that went into effect in 2018 — including a policy expanding the low-volume threshold exemption for small practices— the associations suggested physicians may not be prepared to successfully participate in the program.
“While the undersigned organizations strongly support the increased low-volume threshold and believe it will assist small practices and physicians who treat a small number of Medicare patients, it may create changes in physicians’ eligibility status,” maintained the associations.
According to current MIPS 2018 policy, eligible physicians were required to start collecting and reporting quality data starting on January 1, 2018. However, many physicians were unclear on their eligibility status until several months into the year.
This delay in MIPS eligibility status notification may have hindered certain physicians’ ability to successfully fulfill reporting requirements.
“While we acknowledge that certain reporting options, such as reporting certain outcome-based measures, may require a lengthier reporting period than 90 days to ensure statistical validity, we believe there is a substantial opportunity to reduce the cost and labor involved in reporting MIPS data to CMS by shortening the minimum data collection period to 90 consecutive days and allowing physicians to decide whether to
report additional data,” clarified physicians.
Additionally, implementing a 90-day MIPS reporting period would assist in reducing clinician burden per the aims of the Patients Over Paperwork initiative.
“The 2018 QPP final rule estimates the burden of recordkeeping and data submission will total 7.6 million hours with a cost of nearly $700 million,” stated the associations.
Physicians also pointed out that MIPS feedback reports are due to physicians halfway through 2018. Any modifications physicians may need to make to their administrative processes as a result of these feedback reports would disrupt a year-long reporting period.
“For instance, physician practices may need to conduct internal due diligence to identify quality performance variables, explore more clinically relevant reporting metrics and change data capture and input into the EHR, which would require action by third-party vendors who are not subject to the same payment penalties as physicians,” stated physicians.
With a 90-day reporting period, physicians and group practices would be able to more easily incorporate MIPS feedback into their 2018 performance and focus more on improving patient care delivery rather than fulfilling federal requirements.
“Our organizations are committed to working collaboratively with CMS to ensure MIPS recognizes the quality of care provided to Medicare beneficiaries rather than quantity of data reported,” concluded the associations.