ACP Speaks Out Against Proposed Change in Physician Performance Measures

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Medicare proposal would link reimbursement to patients' hospital readmission rates

Jan. 25, 2019 (ACP) – The American College of Physicians is urging the Medicare agency to rethink its plan to create performance measures that would tie physicians' payments to patients' hospital readmission rates.

ACP's efforts on this issue reflect the College's commitment to advocacy that protects the livelihoods of physicians on the job so they can serve patients to the fullest extent possible, explained Suzanne Joy, a senior associate for regulatory affairs with ACP.

“A lot of our work goes on behind the scenes,” Joy said. “We have a seat at the table, and the Centers for Medicare and Medicaid Services regularly reach out to us to get the perspective of internists. This ongoing relationship is crucial to make sure that our voices are heard as important policies are refined and changed.”

CMS is in the preliminary stages of discussions about adopting a policy that would link physician and physician group payments to the numbers of their patients who have unplanned hospital readmissions. ACP expressed its concerns about the so-called Hospital-wide All-cause Unplanned Readmission (HWR) measure in a Jan. 4 letter to Seema Verma, the CMS administrator.

“The College firmly believes that all measures used to impact physician payments should be based on quality, and cost performance must be appropriately attributed and risk-adjusted, evidence-based, clinically relevant, and statistically reliable and valid,” wrote Dr. Jacqueline Fincher, who chairs ACP's Medical Practice and Quality Committee. “We do not believe the HWR measure meets this standard, and therefore we cannot support it in its current form.”

Specifically, Joy said, “we're concerned about the appropriateness of attributing costs, especially at the individual physician level.” She said that ACP also questions the appropriateness of a measure that does not take into account the different patient populations served by physicians.

“They should measure clinicians on reliable and valid measures,” Joy said. “If measures aren't appropriately adjusted for patient populations, we could see downstream consequences such as cherry-picking and physicians punished for seeing sicker or older patients.”

ACP noted in its letter that it “urges CMS to prove through a robust evidence-based analysis that this measure can be evaluated at the clinician level while meeting stringent validity and reliability standards.”

As part of their effort, ACP officials recently met with colleagues from the American Medical Association and discussed priorities regarding the hospital readmission measure and the need for improvements to the Merit-based Incentive Payment System (MIPS). “We're working to coalesce around common messages,” Joy said. “We share many of the same concerns, and coalition building is important when CMS hears a lot of different perspectives.”

On the hospital readmission performance measure, Joy said it's not clear when CMS might change its policies because there has not yet been a full proposal to consider. The agency may be aiming for 2020 or even 2021, she said.

“We're trying to get ahead of this now by giving CMS preliminary feedback that they can incorporate into their proposals,” Joy said.

That's part of the bigger picture of ACP advocacy, which Joy said is designed to make a difference.

“These measures will impact the bottom line of physician practices,” she said, “which is why we are so dedicated to being a crucial and valued part of the CMS feedback process for continuing to improve MIPS and the QPP at large.”

More Information

ACP's letter to CMS is available on the College website.

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Back to the January 25, 2019 issue of ACP Advocate