Alexandria, VA—The Centers for Medicare & Medicaid Services (CMS) today finalized its rule for the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs) that AMGA contends will slow the transition to value. In its rule for the Quality Payment Program’s (QPP) second year, AMGA believes that MIPS will amount to little more than a regulatory compliance exercise for the small percent of clinicians and groups that participate, as CMS has finalized its proposed increase of the low-volume threshold.
“The transition to value is challenging and CMS understandably wants to ease providers into value,” said Jerry Penso, M.D., M.B.A., AMGA president and CEO. “But excluding providers isn’t the same as learning how to deliver care in a value-based world. Taking accountability for the quality and cost of care requires years of experience. Despite CMS’ intentions to ensure a smooth transition, AMGA is concerned that this rule actually hinders the prospects for value-based care.”
Since CMS proposed its initial rule for the QPP, AMGA members have worked to prepare to report and be judged on each of the four components—quality, cost, advancing care information, and improvement activities—of MIPS. Under MACRA, Congress authorized payment adjustments to Medicare Part B reimbursements based on provider performance in 2018 of 5%. Now, as CMS has implemented the program, even those who perform exceptionally well will receive a nominal update. This serves as a disincentive for high performing providers to invest in the infrastructure necessary to improve care.
Regarding Advanced APMs, while AMGA is pleased that CMS agreed with its position not to determine participation status under the All Payer option at the individual, rather than at the entity level, we are still concerned about introducing an element of choice that may needlessly complicate the process. The models under the advanced APM pathway are designed to evaluate providers as a group and AMGA is concerned how this will be put into practice. Differentiating by individual clinician undermines the care coordination efforts that are at the core of not only the group practice model but of APMs.
AMGA has encouraged CMS to consider clinicians’ contracts with Medicare Advantage (MA) plans that meet the risk, quality, and certified electronic health information technology requirements under the beneficiary count test in 2019 and 2020. In the final rule, CMS responded to the recommendation that AMGA made it its comments on the proposed rule and will develop a demonstration project to test how MA can be included under the APM pathway before 2019. This is a welcome development and AMGA will be following this project carefully.
“Improved access to the Advanced APM pathway would go a long way to giving providers a real choice,” Penso said. “One of the best ways to increase APM participation is to include clinicians’ contracts with Medicare Advantage plans that meet the risk and quality requirements. More and more beneficiaries choose to enroll in Medicare Advantage and factoring these plans into the APM thresholds now would increase the number of providers in risk-based models and help move Medicare away from fee-for-service,” Penso said.