AACU Comments on CMS Proposed Updates to QPP in CY 2018
On August 21, the AACU submitted comments to the Centers for Medicare & Medicaid Services (CMS) on a proposed rule to update the Quality Payment Program (QPP) for the 2018 performance period.
In short, the AACU was generally pleased with the increased flexibility and practical considerations CMS incorporated into its proposal for the 2018 performance period. The goal of the proposal, according to CMS, “is to simplify the program, especially for small, independent, and rural practices, while ensuring fiscal sustainability and high-quality care within Medicare.” The AACU appreciated the proposal’s attempt to provide clarity and improve QPP implementation for providers, and was pleased to see many of our previous suggestions incorporated into the proposed rule.
But while some issues previously pointed out by the AACU were addressed, our concern that QPP implementation is overly complex and out of touch with the realities of actual medical practice nevertheless persists. As such, the AACU hopes that CMS will continue to work with physicians and will truly consider and address the comments submitted by the AACU on behalf of the urology community.
The AACU’s comments on the proposed updates to the QPP for CY 2018 touched on the following points:
- CEHRT Implementation: The AACU thanked CMS for taking into consideration previous comments and public statements made by the urology community advocating for greater flexibility and incentives for 2018 QPP performance period, especially with respect certified EHR technology. We greatly appreciate that CMS took this concern under advisement and proposed allowing MIPS-eligible clinicians to use either the 2014 or 2015 Edition CEHRT in the 2018 performance period.
- Low-Volume Threshold: While the AACU generally supports the CMS proposal to increase the low-volume exclusion dollar threshold from $30,000 in Medicare Part B allowed charges to $90,000, and the low-volume visit threshold from 100 to 200 Medicare Part B patients, we are nevertheless still concerned that the low-volume threshold is still too low for most urology practices to qualify for this exemption. Because urologists see, on average, a greater amount of Medicare patients than other types of physicians, the AACU urged CMS to consider increasing the low-volume threshold even more than it is currently proposing, or at the least to gather urology-specific data on this exemption and analyze its effect on urologists and other specialty physicians.
- Virtual Groups: The AACU in general supports the idea of virtual groups and is generally pleased with the proposal to create and implement these groups. But while we agree with the general intent of the proposal, we expressed our concern that as constructed in the proposed rule, implementation of virtual groups is overly complex and simply not realistically feasible for most providers at this time. Without some type of demonstration that allows clinicians to try virtual group implementation to evaluate its effectiveness, the AACU believes that very few will be willing to form these groups, and those that do may prove unsuccessful, thus deterring a potentially positive option in the long run.
- Advancing Care Information Performance Category: Unfortunately, the current proposal still requires MIPS-eligible clinicians to use CEHRT and report a set of measures that reflect their use of CEHRT in their day-to-day practice. Unless an exemption from the performance category applies, CMS proposes that it would again be weighted 25% of the MIPS composite score. As previously indicated, CMS claims that ACI moves away from the all-or-nothing meaningful use measurement standard, but the base score still requires physicians to report data on mandatory measures. While the AACU is pleased that CMS proposes several new exemptions from the 2018 performance category, we are greatly disappointed that the all-or-nothing approach still remains strongly in place.
- ACI Reporting Requirement: The AACU previously urged CMS to maintain the 90-day ACI reporting requirement beyond the 2017 and 2018 performance periods, and as such supports the proposal to a minimum of 90 consecutive days of data for the 2019 performance period.
- APM Incentive: The AACU believes that while the proposal encourages more participation in APMs, it does not adequately address the significant lack of APM options available to urologists. While there is currently a urology-specific Physician-Focused Payment Model (PFPM) under consideration for adoption—and the AACU strongly supports its approval as an Advanced APM and its subsequent implementation—even if it is adopted as an Advanced APM, there is still only one option for the urology community. We urged CMMI to continue developing APMs that are appropriate for specialists, as well as offer guidance on how existing APMs could be altered to meet the “advanced” criteria.
- AACU Comment Letter (August 21, 2017)
- CMS Proposed Rule on CY Updates to the QPP (CMS-5522-P)
- CMS Fact Sheet on Proposed Rule
- MACRA Quality Payment Program: To Year 2 and Beyond (Hall Render, July 18, 2017)