March 17, 2016
Area(s) of Interest: Advocacy Licensing & Regulatory Issues MACRA
The Centers for Medicare and Medicaid Services (CMS) recently released a draft strategic framework for future quality measure development, as called for under the Medicare payment reform legislation passed last year (the Medicare Access and CHIP Reauthorization Act, also known as MACRA).
The California Medical Association (CMA), the American Medical Association (AMA) and other health care organizations recently submitted comments on this proposal in a joint letter.
CMS's proposed Measure Development Plan (MDP) directly supports the implementation of MACRA's new fee-for-service Merit-Based Incentive Payment System (MIPS), which is supposed to consolidate and simplify the existing Medicare quality reporting programs , including the Physician Quality Reporting System (PQRS), meaningful use and the value modifier, as well as the new alternative payment models (APM). The MDP also highlights known measurement and performance gaps and recommends approaches to close those gaps through development, use and refinement of quality measures. According to CMS, the MPD and the comments CMS receives on it will influence the type of funding CMS distributes for measure development over the next five years.
CMA and AMA were deeply engaged in the legislative process that ultimately led to the enactment of MACRA and believe that for this new law to be successful, physicians will need a strategic quality framework that supports innovation, improves care delivery for patients and leads to more sustainable physician practices.
"We believe a participatory process between physicians and CMS is critical to assuring practicing physicians that quality measures within MIPS and the APMs will be clinically relevant and meaningful for their practice and setting of care, as well as administratively actionable and helpful in providing better care and value for patients,” the AMA comments said.
AMA also criticized the new CMS plan for following the same piecemeal approach to measurement where each Medicare quality program operates in a silo. AMA urged CMS to follow the intent of MACRA, which is to encourage flexibility and provide the chance to redesign and overcome existing problems. Leading quality experts are also calling on CMS to rethink the design of quality programs.
In the letter, AMA asked CMS to improve upon the current quality programs by ensuring that MIPS and APMs take into consideration the various physician specialties and sub-specialties so that all physicians can effectively and successfully participate. AMA also urged CMS to avoid adopting the one-size-fits-all approach as currently constructed under the value-based modifier and meaningful use programs, which have diverted physician efforts and resources away from participating in activities that truly have a positive impact on patient care.
The letter called on CMS to provide more timely and usable data to physicians so that they can improve patient care, instead of narrowly focusing on penalties and rewards. And, it reminded CMS that these goals can only be achieved if accountability is also assigned to the vendors who control what is being required of physicians.
Organized medicine offered an alternative approach that uses a recent Institute of Medicine report as a roadmap for how health care is measured. The letter urges CMS to “start with a broad problem that needs to be solved (such as diabetes or hypertension), set targets for success, identify key roles for physicians as well as other stakeholders, and use measurement to guide us toward our targets."
Regarding the Alternative Payment Models, AMA said that quality measures in an APM should demonstrate that the APM is achieving its goals for care improvement. Experience to date with APMs has found that APM measures are more likely to be based on outcomes of care, such as complication, readmission and reoperation rates, instead of typical PQRS check-the-box measures.
AMA also asked CMS to only allow physician-led organizations to develop quality measures to ensure that the measures are more meaningful to users, uphold national standards and harmonize with clinical data registries.
And, finally, the letter urges CMS to expand its risk adjustment methodology to incorporate race, income and community features to avoid inaccurate conclusions about quality and performance that could unfairly penalize physicians who treat socio-disadvantaged patients and hinder access to care.
To read the letter to CMS on the quality measure development plan, click here.