On June 15th, the Medicare Payment Advisory Commission (MedPAC) released its June report to Congress. MedPAC is an independent agency established by Congress to advise it on Medicare reimbursement policy issues. Each June MedPAC reports on issues affecting the Medicare program as well as broader changes in health care delivery and the market for health care services.
One chapter of the report is dedicated to Medicare’s newly proposed clinician payment systems established under the Medicare Access and CHIP Reauthorization Act (MACRA), which are the Merit-based Incentive Payment System and the Advanced Alternative Payment Model (AAPM/APM).
The underlying theme of the chapter is that MedPAC believes Medicare payments should not be dictated by status of the provider (either MIPS or APM), but rather by the value of service they provide to the beneficiary. The recommendations and opinions reflect that core ideology.
In regards to MIPs, the Commission discusses the limitations of the program to measure clinician performance through process measures compared to outcome measures, but identifies flaws in certain outcome measures as well.
The report considers process measures useful in that they are completely within the clinician’s control; however it also declares that existing measures are often poor indicators of a patient’s health outcomes.
Furthermore, the report states clinician-reported process measures hamper the ability to differentiate performance between different clinicians, as performance on the measures is typically highly clustered, or potentially ―topped out (virtually every clinician reports on the measure). MedPAC believes process measures will do little to improve physician performance and that outcome measures have a stronger impact in encouraging physician improvement.Nonetheless outcome measures are considered statistically unreliable, and MedPAC believes for them to be analyzed properly they should be risk-adjusted.
The key recommendations made in the report in regards to MIPS are:
Improve the value of the quality measure set. Eliminate measures whose collection burden outweighs their benefit.
Consider using more claims-based quality and resource use measures that relate to comparable performance within a local area. This can be done by: exploiting and improving the measures currently in use by using multiple years of data for more accurate performance measures; assessing performance at an aggregate level in a given region to understand patient populations relative to outcomes; or focusing on clinician outliers (determining clinicians whose performance most diverged from their peers and why).
Focus on improving the value of the quality programs. CMS should minimize the burden of quality reporting and maximize the use of claims data to simplify the administration of MIPS, and provide a better transition between MIPS and APMs as clinicians move between the two.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Kirk Reinitz, CPA