AUA, others urge MIPS changes

Forty-nine physician organizations across the medical spectrum, including urology, have urged CMS to reduce the period for reporting quality measures from a full year to a minimum of 90 days for 2018 under the Merit-based Incentive Payment System.

Forty-nine physician organizations across the medical spectrum, including urology, have urged the Centers for Medicare & Medicaid Services (CMS) to reduce the period for reporting quality measures from a full year to a minimum of 90 days for 2018 under the Merit-based Incentive Payment System (MIPS).

In a letter signed by the AUA and the American Urogynecologic Society along with the American Medical Association and 46 other organizations, the groups said the change is needed because CMS failed to post information regarding which programs must comply until April 6.

In addition, the groups requested a reduced reporting period for future MIPS program years in order to reduce administrative burden and ensure physicians have sufficient time to report after receiving performance feedback from CMS.

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The letter pointed out that several policy changes for 2018 “complicate” the ability of physicians to determine if they are eligible for MIPS, including CMS’ expansion of the low-volume threshold exemption for 2018.

Eligibility status could change

“While the undersigned organizations strongly support the increased low-volume threshold and believe it will assist small practices and physicians who treat a small number of Medicare patients, it may create changes in physicians’ eligibility status,” the letter said.

It also noted that the recently enacted 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 for MIPS eligibility.

“As a result, physicians cannot rely on historic estimates from CMS and had to wait on notifications from CMS to determine whether they are excluded under the expanded low-volume threshold,” the letter read.

In addition, the groups complained in the letter that the CMS Quality Payment Program (QPP) website has not been updated with 2018 information, despite the numerous changes in the MIPS program, and that CMS is not expected to update the site until the summer, halfway through the reporting period.

“Given the QPP website is the primary means for educating physicians on the program, this severe delay would undermine physicians’ ability to meet the 2018 requirements to successfully avoid a penalty,” the letter stated. “For individual clinicians and small practices, the delays undercut the relief intended by the expanded low-volume exclusion.”

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Consistent with the Trump administration’s policy of reducing regulatory burdens across the government, CMS announced earlier this year that for QPP Year 2, steps are being made to reduce paperwork burdens on clinicians and the MIPS reporting change requested in the medical groups’ letter would seem to be consistent with that objective.

According to a CMS fact sheet, those changes, in what CMS is calling its “Patients Over Paperwork” program, include excluding individual MIPS-eligible clinicians or groups with $90,000 or less in Part B allowed charges or 200 or fewer Part B beneficiaries; addressing extreme and uncontrollable circumstances, such as hurricanes and other natural disasters, for both the transition year and the 2018 MIPS performance period; including virtual groups as a new participation option; and making it easier for clinicians to qualify for incentive payments by participating in Advanced APMs that begin or end in the middle of the year.

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In addition, CMS said new policies have been adopted to further reduce clinicians’ burden and provide more ways for participation. While keeping many transition-year policies, CMS is making these additional changes:

raising the performance threshold to 15 points in Year 2 (from three points in the transition year)
allowing the use of 2014 edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2, and providing a bonus for using only 2015 CEHRT
giving up to five bonus points on the final score for treatment of complex patients
automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the final score for clinicians impacted by Hurricanes Irma, Harvey, and Maria and other natural disasters
adding five bonus points to the final scores of small practices
giving solo practitioners and small practices the choice to form or join a virtual group to participate with other practices
continuing to award small practices three points for measures in the Quality performance category that don’t meet data completeness requirements.

Overall, CMS said the policy changes mean that:

• Clinicians in affected areas that do not submit data will not have a negative adjustment.

• Clinicians that do submit data will be scored on their submitted data. This allows them to be rewarded for their performance in MIPS. Because MIPS is a composite, clinicians have to submit data on two or more performance categories to get a positive payment adjustment.

• The policy applies to individuals (not group submissions), but all individuals in the affected area will be protected for the 2017 MIPS performance period.

• If a MIPS-eligible clinician who is eligible for reweighting due to extreme and uncontrollable circumstances, but still chooses to report (as an individual or group), they will be scored on that performance category based on their results.

• This policy does not apply to alternative payment models.

In addition, CMS said it is taking steps to increase participation in Advanced APMs, which may allow them to qualify for incentive payments.