Members of the House GOP Doctors Caucus want to see the government lower exclusion thresholds so more clinicians can participate in MIPS.
Five members of Congress—four doctors and a pharmacist—sent a letter (PDF) to Seema Verma, administrator for the Centers for Medicare & Medicaid Services (CMS), on the need for the agency to ensure that more doctors and other clinicians participate in the Merit-based Incentive Payment System (MIPS).
As the Medicare payment system enters its third year, the congressmen urged Verma to make sure the proposed MIPS rule for performance year 2019, which the agency is expected to release soon, provides adequate incentives for providers to participate.
For 2018, CMS estimated that 60% of otherwise eligible providers are excluded from MIPS based on lower thresholds. To reduce the burden on small practices, CMS adjusted that threshold for 2018 to exclude clinicians and groups if they billed $90,000 or less in Medicare Part B-allowed charges and furnished services to 200 or fewer beneficiaries.
“Based on feedback received from provider groups, we are concerned that low-volume thresholds are too high and effectively preclude providers from earning more than a nominal payment adjustment,” they said in the letter. As authorized by the Medicare Access and CHIP Reauthorization Act (MACRA), providers can earn an adjustment of up to 7% on their Medicare Part B payments in 2021 based on their 2019 performance. However, the program relies in part on meaningful participation, and the congressmen worried that current requirements have reduced those payment incentives by excluding many providers from participation in MIPS.
While many of the organizations that represent physicians were happy with the lower thresholds, the AMGA, formerly known as the American Medical Group Association, a trade association that represents multispecialty medical groups and integrated systems of care and is pushing for value-based payment, agreed with the members of the Doctors Caucus that exclusion thresholds should be lowered.
“As CMS develops its MIPS policies for the 2019 performance year, the agency can better tailor the program so that all providers are given the chance to succeed,” said Jerry Penso, M.D., AMGA’s president and CEO, in a statement. “We understand that CMS wanted to move cautiously when implementing the MIPS program, despite the fact that it is effectively a continuation of three pay-for-performance predecessor programs. Now that we are about to enter the program’s third year, it’s time to recognize that continuing to exclude a substantial percent of providers impedes moving the Medicare program to paying for value, which the Congress envisioned in overwhelmingly passing MACRA.”
Penso said the current threshold prevents high performers, including AMGA members, from earning higher payment adjustments, as the exclusions effectively collapse the MIPS payment adjustment distribution curve. As a result, the payment adjustment of up to 5% for 2018 performance instead is projected to be 1.5% for high performers, he said.
Last month, Verma announced that 91% of all clinicians eligible under MIPS participated in 2017, the first year of the program. That slightly exceeded CMS’ goal of 90% participation. Even so, thousands of physicians and clinicians will face penalties for not participating in the first year of the new physician payment system. Eligible clinicians who did not participate will face a 4% cut in their Medicare reimbursement.