- As industry organizations begin their in-depth analyses of the recent CMS proposed changes to the Physician Fee Schedule and Quality Payment Program, several have issued preliminary responses saying the rule could hinder provider payments and ability to deliver quality patient care.
CMS issued its proposed rule on July 12, announcing that the changes will streamline reporting requirements, eliminate provider burden, and allow providers to focus on building better patient relationships.
“Today’s proposals deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients,” said CMS Administrator Seema Verma. “Physicians tell us they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care. This Administration has listened and is taking action.”
Specifically, the rule removed or consolidated some reporting requirements for providers under both the Physician Fee Schedule and the Quality Payment Program, reinforced ideals for better health data interoperability, and better payments for physicians using virtual health to deliver patient care.
However, the rule does not fulfill its promise of creating administrative simplification, according to the Medical Group Management Association (MGMA).
“MGMA is disappointed that CMS plans to continue its burdensome 365-day MIPS quality reporting policy rather than 90 consecutive days,” the group said in a public statement. “Reducing the reporting burden would allow more physicians to participate in MIPS and focus the program on rewarding quality care rather than quality reporting. Requiring medical groups to submit excessive amounts of data to the government has little impact on the quality of care delivered to Medicare beneficiaries.”
The rule also proposes requirements for physicians to adopt EHR upgrades for 2019, many of which could be costly and create more reporting burdens.
These changes will not help providers fulfill the promise of delivering more patient-centered care and building better patient relationships, MGMA contends. Although CMS stated that the proposed rule will give providers more time to meaningfully communicate with their patients, the group said their first glance at the proposal could indicate otherwise.
Additionally, this proposal is a “missed opportunity” for pushing more value-based care throughout the healthcare industry, according to statements from the American Medical Group Association (AMGA).
Proposed changes to the Quality Payment Program do not work to the program’s initial reported intent to help shift more physician payments toward value-based models. Although AMGA has not yet conducted its in-depth analysis of the proposed rule, the group does believe the high low-volume threshold does not advance value-based care throughout the industry.
This could adversely impact providers who are delivering patient-centered and high-quality care for a lower cost, according to AMGA president and CEO Jerry Penso, MD, MBA.
“AMGA members will continue to work to provide superior quality care to their patients,” Penso said in a statement emailed to journalists. “We are concerned that CMS has again opted not to recognize the efforts of high-performing AMGA members. As we enter the program’s third year, it is time for CMS to honor congressional intent and use MIPS to create value for Medicare.”
The American Hospital Association (AHA) did acknowledge some of the positive steps the proposed rule could make, including the potential to improve patient relationships because of more streamlined administrative burden.
“We applaud CMS for taking action to reduce the regulatory burden hospitals and health systems face, including advancing their ‘Meaningful Measures’ initiative,” said AHA executive vice president Tom Nickels. “We also are pleased to see CMS taking some steps to expand the ability of physicians to serve patients through telehealth and virtual connections.”
However, the proposals have their pitfalls, especially as they relate to off-campus hospital outpatient departments.
“We remain disappointed that CMS continues its short-sighted policies on the relocation of existing off-campus hospital outpatient departments,” Nickels said. “These ‘site-neutral’ policies ignore the need for hospitals to modernize existing facilities so that they can provide the most up-to-date, high-quality services to their patients and communities.”
AHA also expressed concern for some drug pricing changes that could reduce reimbursements for certain medications. The organization said CMS should shift its focus to the rising list price for medications.
Additionally, the group expressed concern for the reduction of evaluation and management codes. Getting rid of these codes will reduce disparities in how providers treat patients, regardless of severity of symptoms. A provider treating a patient with minor symptoms could see similar reimbursement rates as a provider treating complex disease, AHA suggested.
All of these organizations emphasized that these comments serve as initial reactions to the proposed rule. Each plan to issue more detailed comments after they have parsed through the more detailed elements of the CMS proposed rule.