AMGA Letter to Congress Offers Key Value-Based Care Recommendations

Feb. 5, 2019
The trade group believes that policymakers should no longer exclude providers from MIPS

The American Medical Group Association (AMGA) has submitted a letter to Congress outlining its legislative priorities, with specific concerns around MACRA and MIPS.

The letter from the Virginia-based association includes extensive recommendations intended to help lawmakers build on earlier legislative achievements and enact needed reforms to enable providers participating in federal programs to deliver the highest quality care to patients in the most efficient and effective manner.

Related to the 2015 MACRA (Medicare Access and CHIP Reauthorization Act) law, to help Congress realize the goals of the law’s Merit-based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (Advanced APM) program, AMGA has offered a series of policy recommendations to ensure there is meaningful provider participation.

According to AMGA, which represents more than 450 multispecialty medical groups and nearly 180,000 physicians, “critical reforms to a variety of federal value-based care programs are needed to ensure a successful transition. Providers that deliver care in a value-based model need a complete understanding of their patient population to best develop and deploy an appropriate care delivery.”

Specifically, AMGA is recommending that Congress ensure that a sufficient number of clinicians participate in MIPS for earnings to be meaningful for high performers. For the Advanced APMs, AMGA suggested that Congress adjust the program’s rules and thresholds for eligibility so that providers have a realistic opportunity to participate and succeed. “AMGA is concerned that absent such reforms, both MIPS and the Advanced APM pathway will not reflect Congress’ original intentions to move the payment system to one based on value,” according to a press release from the association.

As explained in the letter, under the MIPS program, providers have the opportunity to earn an annual adjustment to their Medicare Part B payments based on their performance starting in 2019, with a positive or negative adjustment range of 4 percent. That range eventually increases to 9 percent in 2023. As AMGA wrote, “By creating a system where high performers were rewarded, and poor performers who received a lower payment rate were incented to improve, MACRA was designed to transition Medicare to a value-based payment system.  Despite the MACRA statute, CMS has excluded approximately 60 percent of providers from MIPS requirements in the past few MACRA regulations.”

Via past regulations on MACRA/MIPS, CMS has implemented various provisions that exclude clinicians who don’t meet the government’s low-volume threshold for Medicare patients, or its threshold for Medicare Part B allowed charges for covered professional services, from participating in MIPS. In CMS’ final rule for the third year of MACRA’s Quality Payment Program (QPP), federal officials added a third criterion for clinicians to qualify for the low-volume threshold for MIPS exclusion: providing 200 or fewer covered professional services under the Physician Fee Schedule. Between these excluded physicians, and those in the A-APM track, there are indeed a large number of providers who won’t be participating in MIPS right now.

According to the AMGA letter, “Because MIPS is budget neutral, these exclusions result in insignificant payment adjustments to high-performing providers.” It went on to say, “These insignificant payment updates fail to reward providers for superior performance in the MIPS program and provides nominal return on investments. Unfortunately, MIPS has devolved into an expensive regulatory compliance exercise with little to no impact on quality or cost. Policymakers should no longer exclude providers from MIPS.”

What’s more, regarding the A-APM track, AMGA feels that thresholds to be a part of this payment track “are unlikely to be met and will not attract the critical mass of physicians and medical groups necessary to ensure success. This is due to a dearth of commercial risk products and limited Medicare Advance APM options.”  As it stands now, in 2019, 25 percent of a provider’s Medicare revenue must come from APMs for a provider to be eligible. In 2021, 50 percent of revenue must come from APMs, and this threshold increases to 75 percent in 2023.

The letter also touched on meaningful use (MU) Stage 3 EHR documentation requirements, as AMGA is “unconvinced that the substantial investment in time required to complete Stage 3 MU documentation actually improves patient care and patient outcomes.” The comments also stated, “Additionally, HIT vendors have been slow in updating their products to meet Stage 3 requirements. Since the benefits of requiring Stage 3 MU is both uncertain and since Stage 3 product selection limited, we believe that policymakers should suspend this HIT requirement.”

“This new Congress has the opportunity to build on past gains and continue the shift to value-based care,” AMGA President and CEO Jerry Penso, M.D., said in a statement. “AMGA’s recommendations serve as roadmap for policymakers who want to move past the vision of value-based care and help enact policies that will deliver the benefits of a value-based system to providers and patients across the country.”

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