NCQA Offers Comments to CMS on Quality Payment Program 2018 Rule

In comments to the Centers for Medicare & Medicaid Services (CMS), the National Committee for Quality Assurance (NCQA) has offered several suggestions that it thinks the federal agency should consider before writing the final Quality Payment Program (QPP) rule for 2018.

In June, CMS dropped the proposed 2018 rule for the QPP, designed with a core focus to simplify the program—especially for small, independent and rural practices. As part of this assistance for smaller practices, CMS confirmed that it will offer virtual group participation next year, which would allow solo practitioners and small practices to join together to report on MIPS (Merit-Based Incentive Payment System) requirements as a collective entity—which in theory would ease the burden for these physicians.

In its recent comments to CMS, NCQA said “this is a key step toward helping small practices advance toward accountable, team-based, patient-centered care models. NCQA patient-centered medical homes (PCMHs) and patient-centered specialty practices (PCSPs) have demonstrated commitment to improving cost and quality and therefore make ideal virtual group partners. We look forward to exploring how NCQA can support CMS and clinicians in creating virtual groups. We urge you to provide bonus points as incentive for clinicians to join virtual groups. We also urge you to encourage, rather than prohibit, low-volume clinicians’ participation in virtual groups.”

The committee also said that CMS should provide auto-credit in the Advancing Care Information category (formerly meaningful use) for MIPS participants to PCMHs and PCSPs because of the strong focus on use of health IT in standards for these programs. “ACI auto-credit would reduce unnecessary burden for clinicians who have already completed the rigorous PCMH or PCSP recognition process,” NCQA said in its comments.

The committee further feels that a more comprehensive approach to determining which measures are topped out is needed. Currently, clinicians choose which measures they report and how they report them. Said NCQA, “This voluntary reporting may lead clinicians to ‘cherry pick,’ reporting only measures on which they perform best or only on a sample of the relevant population. An accurate picture of topped out measures requires more universal data collection with mandatory reporting on a clinician’s entire population.”

What’s more, regarding MIPS performance thresholds, the committee supports the proposal to establish a 15-point threshold for avoiding performance penalties for 2018. “However, we urge you to increase the threshold in future years to ensure there are appropriate incentives for clinicians to improve performance on MIPS measures,” it said.

For more of NCQA’s comments on the QPP 2018 proposed rule, click here. CMS is taking comments until Aug. 21 on the proposed rule before the federal agency finalizes the program for 2018.