- The American College of Rheumatology (ACR) has expressed concerns over provisions of MACRA implementation that could negatively affect the performance of specialists in either the Merit-based Incentive Payment System (MIPS) or Alternative Payment Models (APMs).
In a letter to the Centers for Medicare & Medicaid Services (CMS), the organization highlight four major components of MACRA implementation likely to adversely impact rheumatologists.
The first centers on timing. “We are concerned that the proposed timeline will impede rheumatologists’ ability to prepare and comply with the extensive new requirements,” wrote ACR President Joan M. Von Feldt, MD, MSEd.
To mitigate concerns over the upcoming performance year, the organization has asked the federal agency to consider a reduction in the 2017 reporting period as one potential solution but only if done so carefully:
We recognize that most quality measures are specified for certain reporting periods or minimum sample sizes, and reducing reporting periods may impact performance on the measures in a way that does not accurately reflect true quality. Therefore we request that in implementing this delay in the timing for the first performance year, for any measures where a change in the denominator volume or duration of reporting period could unduly influence performance on the measure, some provision(s) in the reporting or performance requirements be made.
Secondly, ACR considers CMS proposals for Advanced APMs — the only APMs capable of satisfying requirements of the Quality Payment Program — to represent a significant barrier to entry and require CMS to alert eligible clinicians whose APMs don’t qualify:
Fundamental to APMs being successful is that the models are flexible and have easy to understand criteria. As proposed, the rule provides that Physician Focused Payment Models (PFPMs) may not necessarily meet the criteria to be considered an Advanced APM. It is important to note that providers are unlikely to pursue a PFPM if it does not qualify as an Advanced APM.
Thirdly, proposed MIPS requirements for resource use do not take into account the clinical decision-making of certain specialists — specifically the use of Part D drugs which are currently not included in this MIPS performance category:
Without including Part D costs in the resource use category, this measurement will unfairly penalize providers such as rheumatologists whose patients depend on Part B services. Rheumatology, unlike many other specialties, has few treatment options to choose from and the drugs and biologics we and our patients depend on are often times more expensive than those used by other specialties. True and complete evidence-based patient care requires us to use these medications and we should not be penalized for doing so.
The proposed MACRA rule would include Part B drugs, which the organization has contended would provide a limited view into the resource use of rheumatologists.
The consequences of the proposed approach could extend beyond MACRA implementation and MIPS as a result of CMS plans to share performance data with the public via Physician Compare, ACR leadership stated:
In order to provide patients with meaningful information, we believe that data which are potentially misleading or do not help patients make decisions about their healthcare be withheld. One example of data which we believe would not benefit patients is global resource use data. Presenting these data is likely to cause confusion and create misleading interpretations of physicians’ performance. To appropriately interpret data on resource use, data must also be provided that contextually describes factors such as relative complexity of the patient population and achievement of quality measures, which in part drive that cost.
The MACRA-, MIPS-, and APM-related concerns raised in the ACR letter include reporting mechanisms, selecting clinical quality measures, and reviewing and correcting MIPS composite performance scores.