The Alliance of Specialty Medicine wrote a letter to Dr. Francis Crosson, the chairman of the Medicare Payment Advisory Commission (MedPAC) questioning the advisory board’s suggestion to repeal the Merit-based Incentive Payment System (MIPS), which is one of the payment tracks in MACRA.
At its October meeting, MedPAC recommended moving physicians to advanced alternative payment models (APM), eliminating MIPS and replacing the payment program with a voluntary value program.
The Alliance of Specialty Medicine, which represents more than 100,000 specialty physicians from 13 specialty and subspecialty societies, said the move would require participation in APMs or engagement in population-based measurement via large entities to avoid financial penalties.
MedPAC members said MIPS, which allows providers to earn performance-based payment adjustments to Medicare payments, is too burdensome and won’t improve care. They also said MIPS doesn't focus enough on patient care and centers around whether providers order tests and follow clinical guidelines.
Instead, the nonpartisan advisory board suggested a new program by which a portion of payments (such as 2%) is withheld. Providers not in an APM could join a group of physicians whose claims data is reviewed on population-based health measures to see if they qualify to have the withheld funds returned. Providers who do not participate in an APM or the new model would forfeit the withheld portion.
In its letter, the Alliance of Specialty Medicine said it opposes MedPAC’s recommendation for multiple reasons, including that APMs don’t allow for specialists “to meaningfully engage.” Also, population-based measures are limited in evaluating quality and cost of specialty care, which will hinder specialists’ performance in large entities.
Third, MACRA promotes “the development of clinically relevant, specialty-based quality measures.” Plus, most physicians are not in large entities and fee-for-service “remains a viable reimbursement structure for many specialists and subspecialists where alternative models of care and payment have already addressed the value equation for the vast majority of their services,” wrote the group.
“The MIPS program provides the only mechanism for many specialists and subspecialists to engage in federally-sponsored quality improvement activities and demonstrate to beneficiaries their commitment to delivering high-value care. Eliminating MIPS in favor of MedPAC’s proposed new quality program would discourage specialty physicians from developing robust quality and outcomes measures, including the establishment of high-value clinical data registries, and would thwart efforts to collect and report performance data,” the alliance wrote.
But MedPAC members aren't the only ones concerned about MIPS. Providers have mixed feelings about the payment program. Many physicians support moving to value-based payment models, but they complain that MIPS’ reporting requirements are too stringent.
A recent Medical Group Management Association survey found group practices feel MIPS is too complex, doesn't benefit patient care and doesn't support individual practice’s clinical quality priorities.
Some in the industry, however, worry that value-based payment initiatives will be set set back if MIPS is sidelined. AMGA, for example, opposed increased exemptions to MIPS, saying the move "fails to recognize the significant investments made in preparation for participation" in MACRA.