Forty-four medical associations and societies are urging the Centers for Medicare and Medicaid Services to make major changes to the Merit-based Incentive Payment System, known as MIPS, a payment program that rewards doctors for quality care and improved outcomes.
The MIPS program includes a component for the effective use of information technology in care practices.
In a letter to CMS Administrator Seema Verma, the organizations call for the agency to reduce the quality measure reporting period for MIPS in 2018 from a full calendar year to a minimum of 90 consecutive days, in part because CMS itself is not fully prepared to administer the program.
For example, the associations note there has been a lack of timely and direct notification by CMS on whether a physician is considered MIPS eligible, as well as a significant delay by CMS in updating the Quality Payment Program (QPP) interactive web site with 2018 information. The groups contend that policy changes made by CMS in 2018 complicate the ability of doctors to determine their MIPS eligibility status.
“It is our understanding that CMS does not plan to update the QPP website with 2018 information and measures until the summer, at the earliest,” the associations contend.
Going further, the medical associations and societies ask for a reduced reporting period in future reporting years to reduce administrative burden and ensure physicians have sufficient time to report after receiving performance feedback from CMS.
Physicians also are not pleased that they must now go to the CMS website to determine if they are eligible for the MIPS program. Previously, CMS mailed letters to inform them of their eligibility status. “Without direct outreach by CMS to physicians and group practices, many physicians will be left in the dark on their status,” the letter states.
The physicians also are concerned that the Bipartisan Budget Act of 2018 modified MACRA to exclude Medicare Part B drug costs from MIPS payment adjustments and from the low-volume threshold determination of MIPS eligibility. “As a result, physicians cannot rely on historic examples from CMS and had to wait on notifications from CMS to determine whether they are excluded under the expanded low-volume threshold,” the letter states.
The associations and societies also reminded CMS of its commitment to reduce clinical burden and put patients over paperwork. The final rule for the Quality Payment Program estimates recordkeeping and data submissions will reach 7.6 million hours and a cost of nearly $700 million.
“This estimate may be low as a 2016 Health Affairs study found that each year physician practices in four common specialties spend, on average, 785 hours per physician and more than $15.4 billion on quality measure reporting programs,” according to the letter. ”As the study cites, the majority of time spent on quality reporting consists of entering information into the medical record only for the purpose of reporting for quality measures from external entities.”
The complete letter and a list of the 44 participating medical associations and societies are available here.
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