A specialty group opposes a recent recommendation of the Medicare Payment Advisory Committee to eliminate the complex Merit-Based Incentive Payment System in favor of an alternative payment system.
MedPac members believe that MIPS, one of two payment tracks under the Medicare Access and CHIP Reauthorization Act, is a burden for doctors and doesn’t accomplish the Centers for Medicare & Medicaid Services’ goal of rewarding high-value physicians and improving care.
But while the Alliance of Specialty Medicine, which represents more than 100 specialty physicians and subspecialty societies, appreciates that MedPac recognizes the challenges physicians face with participation in MIPS, it said the proposal to replace the program isn’t the solution.
The MIPS program provides the only mechanism for many specialists and subspecialists to engage in federally sponsored quality improvement activities and demonstrate to beneficiaries their commitment to delivering high-value care, according to a letter (PDF) the alliance sent last week to MedPac Chairman Francis J. Crosson, M.D.
“Specialty physicians are working with CMS and Congress to improve MIPS and allow for more meaningful and robust engagement,” the letter said. “We are encouraged by the dialogue and positive trajectory. MedPAC’s proposal would be a significant step backwards and will be opposed by the vast majority of physicians, including the alliance.”
The alliance said it is strongly opposed to MedPac’s push to replace MIPS with a “Voluntary Value Program," which requires physicians to participate in advanced alternative payment models (A-APMs) or engage in population-based measurement via large entities to avoid financial penalties. The alternative policy option is a problem for several reasons:
- Few A-APMs exist, so specialists wouldn’t be able to meaningfully engage in the process.
- The limitations of population-based measures in determining quality and cost of specialty medical care will hinder specialists’ performance in “large” entities.
- MACRA clearly intended to promote the development of clinically relevant, specialty-based quality measures.
- Most physicians do not practice in “large” entities and therefore will impede individual doctors or groups from successful participation.
- Fee-for-service remains a viable reimbursement structure for many specialists and subspecialists where alternative models of care and payment have already addressed the value equation for the vast majority of their services.