Washington, DC (August 7, 2020) —The American College of Physicians (ACP) says that while the proposed changes to the Medicare Quality Payment Program (QPP) make some initial accommodations to help physicians who are dealing with the effects of the COVID-19 pandemic on their practices, that still more needs to be done. The proposed Quality Payment Program rule for 2021 was released earlier this week.
“Physician practices are reeling this year thanks to the COVID-19 pandemic, and they are having to make major shifts in how they conduct business” said Jacqueline W. Fincher, MD, MACP, president, ACP. “With the financial ramifications of the decrease in-person office visits, the shift to telehealth, and the major practice design changes that must be made to deal with the novel coronavirus, the resources a practice has to handle other practice transformation activities are severely compromised.”
The proposed QPP rule for 2021 does include some accommodations to help practices dealing with COVID-19. Among those, CMS would reduce the Merit-based Incentive Payment System (MIPS) performance threshold slightly, from 60 to 50 points, and would use performance year data to score quality measures instead of relying on historic benchmarks. The changes proposed for 2021 reporting criteria were minimal and CMS offered no broad scale exclusions or protections for the 2021 performance year in the proposed rule. .
CMS also proposes to delay the start of the new MIPS Value Pathway until at least 2022.ACP supports the MVP concept as an opportunity to reduce burden and were one of only a few organizations to offer its own draft MVP proposal earlier this year. CMS attributed the delay in the start date to the challenging circumstances presented by COVID-19 and emphasized the importance of a gradual implementation, which aligns with previous ACP recommendations.
Substantial changes were proposed to quality reporting for Accountable Care Organizations (ACOs) and other Alternative Payment Models (APMs), including retiring web interface reporting. The changes are intended to reduce reporting burden, but ACP has concerns that the reduced measure set eliminates reporting flexibility and that the timeline for ACOs to implement these sweeping changes is too short. CMS offered no additional protections for APM participants from financial risk requirements or performance-based payment adjustments. The proposed rule also did not address the scheduled increase in the Qualified APM Participant (QP) thresholds next year, which is expected to result in far fewer clinicians qualifying for the Advanced APM bonus. ACP has previously requested that APMs be broadly exempted from risk-based payments and receive protection against performance-based penalties and has encouraged the Department of Health and Human Services to exercise its authority to adjust the patient count QP threshold.
“ACP has long supported the move toward value-based payments, and we continue to do so. But right now, our practices are in crisis,” continued Dr. Fincher. “The effects of the COVID-19 pandemic on our health care system will carry through for quite some time. Right now practices need support—not penalties—as they continue to recover and rebuild. We hope that CMS hears our concerns and that we can work with them to include more effective accommodations for physician practices in the final rule.”
About the American College of Physicians
The American College of Physicians is the largest medical specialty organization in the United States with members in more than 145 countries worldwide. ACP membership includes 163,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow ACP on Twitter, Facebook, and Instagram.
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