- Members of the Alliance of Specialty Medicine recently submitted a letter to Medicare Payment Advisory Committee (MedPAC) Chairman Francis J. Crosson, MD, arguing CMS should improve the Merit-Based Incentive Payment System (MIPS) rather than cancel it entirely.
The alliance representing more than 100,000 specialty physicians from 13 specialties and subspecialties including neurology, dermatology, osteopathy, and others.
Alliance’s letter comes in in response to a MedPAC presentation at a public meeting earlier this month during which the committee offered a new policy option to replace MIPS called the Voluntary Value Program (VVP).
VVP would be designed to move physicians into advanced Alternative payment Models (APMs). The new program would require participation in APMs or engagement in population-based measurement through large entities to avoid payment penalties.
“We appreciate that the Commission recognizes the challenges physicians face with participation in the MIPS program, including the complexity of reporting requirements and tremendous cost burden,” stated the alliance. “We also appreciate the difficulty beneficiaries may experience when using quality and performance measures and their resultant scores to make informed choices about their care.”
However, the alliance stated it strongly opposes the recommended alternative policy option. First, the alliance pointed out there are few advanced APMs for specialists to meaningfully engage, with some specialists having no chances to participate in advanced APMs at all.
“Most other models that have been identified as advanced APMs are focused on primary care providers, not specialists,” wrote alliance members.
The alliance also emphasized the limited ability of population-based measures to determine the quality and cost of specialty care. Additionally, alliance members stated population-based measures will be a detriment to specialists performing in the suggested large entities.
“Most population-based quality and cost measures are designed around chronic, comorbid conditions that are largely under the management of primary care providers, leaving the vast majority of specialty physicians without opportunities to demonstrate a direct and positive impact on the value of care they deliver,” they stated.
Alliance members also noted it would be challenging for most specialty providers to demonstrate the value of their care under current quality measures used in advanced APMs.
Next, members pointed out that MACRA was initially designed to promote the development of clinically relevant, specialty-based quality measures. VVP would divert from this work.
“Members of the Alliance are heavily invested in this work, producing quality measures that improve clinical care, patient experience, and ultimately, beneficiary understanding of the care they can expect to receive by qualified providers,” they wrote. “MedPAC’s policy direction would dismantle these efforts, which are broadly supported by government, providers, patients, and payers.”
The alliance also stressed that the majority of physicians do not practice in the large entities recommended by MedPAC’s alternative policy option, which would inhibit physicians practicing in smaller groups from succeeding under VVP.
Members pointed to data from the American Medical Association showing most physicians still work in small practices, and single-specialty practices were the most common practice type in 2014.
“As a result, a significant proportion of beneficiaries receive healthcare from physicians in small practices,” stated alliance members. “This is a viable model of healthcare delivery that must be preserved; not all physicians should join or form large entities.”
Finally, the alliance suggested the fee-for-service payment model is still a viable reimbursement structure for many specialty providers. Alternative models of care and payment have addressed the value equation for most of their services, they stated.
Some specialists have moved services from inpatient settings to lower-cost outpatient settings and begun reducing gaps in care through long-term performance improvement.
“In some cases, these specialists have eliminated variation in cost and clinical quality across geographic regions, which is documented in the literature,” they wrote. “For these specialists, fee-for-service remains the most appropriate reimbursement structure.”
Alliance members stated intentions to work with CMS and Congress to improve MIPS rather than eliminate the program.
“Eliminating MIPS in favor of MedPAC’s proposed new quality program would discourage specialty physicians from developing robust quality and outcomes measures, including the establishment of high-value clinical data registries, and would thwart efforts to collect and report performance data,” they wrote.