Medicare Compliance & Reimbursement

Most physician and hospital groups oppose the commission's drastic suggestions.

Medicare providers are rounding the bend on the MIPS learning curve with one year and four months into the quality-backed payment plan. But despite strides made by many to adopt and adapt, one federal think-tank suggests ditching Medicare's basic reimbursement regime.

Background: Last year, MACRA's Merit-Based Incentive Payment System (MIPS) went into effect, replacing CMS's previous plan, the Sustainable Growth Rate (SGR), as Medicare's entry-level reimbursement system. Mixed results and some confusion ensued, but despite bumps in the road, quality care and cost adjustment were realized under the new arrangement. And to assist with MIPS transitions, the Bipartisan Budget Act of 2018, which was signed by President Trump in February, slowed down implementations, the weight of the cost category as it factors into the total MIPS score, and changed low-volume threshold language (See p. 50).

But, despite some MIPS success and federal rollbacks and slowdowns outlined in the Bipartisan Budget Act, the Medicare Payment Advisory Commission (MedPac) recommended in its March 2018 Report to Congress: Medicare Payment Policy to get rid of MIPS and replace it with something less complicated and voluntary.

Look at the Details

The commission insists that the reasoning for its message is to encourage more Quality Payment Program (QPP) participation while supporting Medicare's reimbursement endeavors. One of the primary arguments for MIPS elimination, MedPac says, is that it only encourages providers to engage in and report quality measures they know they'll do well in, ensuring steady Medicare pay. Instead of putting patients first, clinicians will "focus on selecting measures on which they expect to do well (rather than focusing on improving patient outcomes)," cautions MedPac in its report.

They will "remain in traditional FFS [Fee-For-Service] in bonus-only payment models that will increase their probability of getting high MIPS scores (instead of joining meaningful A–APMs [Advanced Alternative Payment Models] with both risk and reward)," warns the commission.

In MIPS place, MedPac suggests a "voluntary value program" or VVP. The new initiative would be more inclusive and less restrictive and burdensome than the current program, the commission proposes. This would allow for greater participation, more stakeholder decision making, and less administration.

Nuts and bolts: Take a look at the top five takeaways from MedPac's report to Congress. The commission suggests a MIPS replacement include:

• A "value component" for FFS payment
• Option to "self-organize into groups"
• Uniform requirements across the board for all specialties
• Claims-based measures that don't require extensive tools for reporting
• Caps on payment increases and penalties to encourage greater participation in Advanced APMs

Physician Groups Counsel Against Rash Decisions

The American Medical Association (AMA) sees MedPac's move as a gut punch to Medicare clinicians already on board with MIPS. "No major physician organization has supported the MedPAC proposal, nor is there significant support for the proposal on Capitol Hill where MedPAC's suggestion is viewed as unrealistic," AMA proclaimed in an "Advocacy Update" post. The physicians' group warned, MedPac's proposals were "late to the table," and "unfair and confusing to physicians who have already invested money and resources to participate in MIPS."

Other advocacy organizations agree with the AMA and think a MIPS reversal is a mistake. "MedPAC's March Report is an indictment of MIPS as implemented," said Anders Gilberg, Senior Vice President of Government Affairs for Medical Group Management Association (MGMA) in a statement on MedPac's report. "However, its conceptual 'VVP' alternative lacks details."

Gilberg urged CMS to decrease reporting measures rather than ditch MIPS for another, untested program. "MGMA believes there are steps that can be taken now to reduce clinician burden. CMS can begin by shortening the 2018 MIPS data reporting period from one-year to 90 days in the same way the Agency did for Meaningful Use in 2014, 2015, and 2016."

Resource: To read MedPac's March 2018 Report to Congress: Medicare Payment Policy, visit http://medpac.gov/docs/default-source/reports/mar18_medpac_entirereport_sec.pdf?sfvrsn=0.