- Stakeholders including the National Committee for Quality Assurance (NCQA) recently released comments on the Quality Payment Program (QPP) 2018 final rule that include suggestions to change the new low-volume threshold.
On November 2, CMS released the QPP 2018 final rule and announced the start of a comment period to allow for continued stakeholder feedback. Stakeholder comments about the stringency of some federal regulations contributed significantly to changes made for the second year of QPP.
“Since January 1, 2017, we’ve worked with more than 100 stakeholder organizations and over 47,000 people to get the word out about the Quality Payment Program, get feedback, and help make it easier for you to participate,” stated CMS.
In its comment letter, NCQA commended CMS for policies in QPP surrounding Medicare Advantage alternative payment models (APMs), NCQA eMeasure certification, patient-centered medical homes and specialty practices, NCQA patient-centered connected care, and virtual groups.
NCQA was especially appreciative of the federal agency’s interest in encouraging NCQA’s eMeasure Certification to enable organizations to obtain performance measurement data automatically from EHRs.
“This will greatly reduce clinicians’ reporting burden, improve the accuracy of results, and allow better measurement of outcomes that people most care about,” stated the committee.
Additionally, NCQA stated its support of the final rule’s provision that 50 percent of practices within a Tax Identification Number (TIN) must have recognition for all practices to receive auto-credit for the clinical practice improvement activities category part of MIPS.
“Previously, only 1 practice within a TIN needed recognition,” wrote NCQA. “The new rule brings the program closer to Congress’ intent when it stipulated auto-credit for PCMHs and PCSPs in the law.”
Similarly, NCQA also applauded the final rule’s provision offering auto-credit for practices in NCQA’s Patient-Centered Connect Program.
“The rule recognizes the effort and benefits of PCCC practices by providing auto-credit for both Clinical Practice Improvement Activities and Advancing Care Information categories of MIPS,” NCQA stated.
While NCQA largely supported the QPP final rule, the committee requested CMS amend one policy pertaining to virtual groups.
Presently, CMS allows small practices to form virtual groups to participate in MIPS and prepare for APMs. However, the rule stated low-volume practices are ineligible for MIPS.
“Low-volume practices – those with less than $90,000 in Medicare revenue or 200 Medicare patients –most need virtual groups so they can have reliable measurement and reap rewards for improvement,” wrote NCQA. “CMS could remedy this by amending its low-volume definition to say these practices are ineligible for MIPS ‘unless they join a virtual group.’”
Former CMS Deputy Chief of Staff and current Caravan Health Senior Vice President of Strategy and Development Tim Gronniger also released a statement about the final rule.
“The final rule for 2018 makes clear that for the vast majority of clinicians MACRA is here to stay, so it’s time to start planning for how to succeed rather than hoping CMS makes it all go away,” Gronniger said in an emailed statement to EHRIntelligence.com.
The Medicare Payment Advisory Commission (MedPAC) was one such organization that called for MIPS to be eliminated in place of an alternative option. The commission recommended MIPS be replaced with a voluntary value program (VVP) that would better align quality and value signals across the healthcare delivery system and reduce clinician burden.
In addition to urging clinicians to accept MACRA instead of pushing for different options, Gronniger also stated his disapproval for the federal agency’s decision to increase the low-volume threshold to clinicians with fewer than $90,000 in Medicare payments or less than 200 Medicare patients.
“While we would have preferred CMS not increase the low-volume threshold, clinicians who see any significant number of Medicare patients are still in the program, and clinicians who are excluded will see their compensation frozen for the coming five years,” he stated.
Portions of the QPP 2018 final rule were informed by the new CMS Patients Over Paperwork initiative designed to reduce unnecessary regulatory burden and increase efficiency. The increased low-volume threshold and the new CMS policy allowing eligible clinicians to submit hardship exemptions due to “extreme and uncontrollable circumstances” such as natural disasters are both part of this initiative.
The American College of Physicians (ACP) recently issued a letter to CMS expressing support for the new initiative.
"ACP has long been in favor of trying to reduce unnecessary regulatory burdens on physicians," said ACP President Jack Ende, MD.
ACP has had a Patients Before Paperwork initiative in place since 2015. Leading up to the launch of the CMS initiative, ACP was in communication with HHS and CMS requesting reduced administrative burden.
"We agree with the Administration that overly burdensome administrative tasks interfere with the patient-physician relationship, diverting the physician's time and attention away from the actual patient care,” said Ende. “It is important to minimize these distractions to avoid negatively impacting patient care."