On October 2, ISASS and 118 state and specialty societies wrote to Congress urging the enactment of legislation to ensure that the Centers for Medicare and Medicaid Services (CMS) has the flexibility to continue a transitional approach to the implementation of the Quality Payment Program (QPP) required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The letter was addressed to the Committee on Energy and Commerce and also went to chairs and ranking members of the House Ways and Means and Senate Finance committees.
MACRA was bipartisan legislation signed into law in April 2015 to permanently repeal the Sustainable Growth Rate (SGR), streamline physician quality reporting programs, and provide incentive payments for physician participation in alternative payment models. MACRA sunsets the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier, and the Medicare Electronic Health Record (EHR) Incentive Program and establishes an umbrella Quality Payment Program (QPP) with two new pathways for payment: 1. Merit-Based Incentive Payment System (MIPS) and 2. Advanced Alternative Payment Models (Advanced APMs).
At the insistence of medical societies and other stakeholders, CMS has taken a flexible approach to implementing the QPP. 2017 has been designated the “transition year” by allowing “pick your pace” reporting. In order to continue this flexible approach to implementation, Congress needs to make some statutory changes to MACRA including:
1. allowing CMS to continue to weight the Cost category of MIPS to zero percent while episode-based cost measures are still under development. This means that physicians won’t be measured on the cost of patient care until appropriate measures are available to do so; and
2. allowing CMS to continue to select a performance threshold lower than the mean or median while more physicians gain familiarity with the program. The performance threshold dictates whether penalties or incentive payments are made to physicians— physicians falling below the performance threshold are penalized and physicians falling above the performance threshold are awarded incentive payments. (The 2017 performance threshold is set at 3 points and CMS has proposed the 2018 performance threshold at 15 points.)