Washington, D.C. November 7, 2019 – The American College of Physicians (ACP) appreciates the Centers for Medicare and Medicaid Services’ (CMS) changes to the Merit-based Incentive Payment System (MIPS) announced in the 2020 Quality Payment Program (QPP) final rule, but calls for more efforts to improve performance measurement and strengthen primary care.
ACP is encouraged by certain 2020 MIPS changes that will help to improve performance measurement, including:
- Reversing its proposal to increase the weight of the Cost Category to 20 percent, and instead keep it at its current weight of 15 percent—allowing clinicians time to familiarize themselves with significant changes to the category.
- Introducing significantly redeveloped claims-based cost measures. While these measures are a marked improvement, ACP opposes attributing broad-based downstream costs, particularly at the individual clinician level, and will continue to push for more targeted condition- or specialty-specific cost measures.
- Removing performance measures deemed to be low-value in response to ACP concerns about low validity and clinical accuracy. However, ACP continues to advocate that there be a sufficient number of patient-centered, actionable, appropriately-attributed, and evidence-based measures available for all subspecialists.
- Removing the “Verify Opioid Treatment Agreement” measure from the Promoting Interoperability (PI) measure set, which would have been a low-value and burdensome measure had it been required. ACP hopes CMS will consider feedback and recommendations for improving the PI category in future years.
“ACP appreciates the improvements to MIPS that were a direct response to previous ACP advocacy efforts,” said Robert McLean, MD, MACP, president, ACP. “We will be analyzing the changes more closely to ensure they are implemented in a way that will truly enhance performance measurement while strengthening the patient-physician relationship.”
However, ACP fears other changes set to take effect next year will increase reporting burden and potentially hurt small and rural practices. Specifically, the College is concerned that:
- Increased data completeness requirements for the Quality Category will increase reporting burden and reduce flexibility to weather temporary disruptions in data reporting caused by vendors or other unforeseen events.
- Increasing the group reporting threshold for the Improvement Activities Category from a single clinician to half of the clinicians in the practice will drastically increase reporting burden for this category and fail to recognize scenarios where the functioning of an entire practice can be vastly improved through the actions of one or a few clinicians.
- Increasing the regular and exceptional performance thresholds for the MIPS composite score without adding additional flexibilities for small and rural practices will exacerbate the existing performance gap.
ACP hopes that the new MIPS Value Pathway (MVP), which was finalized for implementation starting in 2021, could help to reduce burden in MIPS and help physicians transition to Alternative Payment Models (APMs).
“ACP is optimistic that the goals of the MVP—including reducing clinician burden, streamlining the performance categories, and providing more consistent performance feedback—will help to strengthen primary care. We are particularly excited that CMS is open to implementing a trial or transition period for the MVP and is intent on receiving stakeholder feedback, which will be paramount to the future success of this new pathway,” said Dr. McLean. “We look forward to working with CMS to ensure that MVPs are designed with both patients and physicians in mind.”
Additionally, the final 2020 QPP rule will restrict private sector medical homes from qualifying as APMs unless they formally align with Medicare. ACP feels this defies congressional intent by failing to reward clinicians who participate in innovative payment and delivery arrangements, including private payer medical homes.
“It’s more important than ever to address administrative burdens while ensuring quality patient care,” said Dr. McLean. “We need to promote participation in APMs and reduce MIPS reporting burden, not add to it, in order to improve patient care.”
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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 159,000 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.