SIR Recommends Changes to CMS’s Proposed New Payment Rules
June 28, 2016—The Society of Interventional Radiology (SIR) announced that it has submitted comments to the Centers for Medicare & Medicaid Services (CMS) recommending changes to the Quality Payment Program proposed rule.
On April 27, the US Department of Health and Human Services announced that it was issuing a Notice of Proposed Rulemaking to implement key provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), bipartisan legislation that replaced the flawed Sustainable Growth Rate formula with a new approach to paying clinicians for the value and quality of care they provide. The proposed rule would implement these changes through the unified framework called the Quality Payment Program, which includes two paths: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). The CMS Fact Sheet on the proposed program is available online here.
In the society’s announcement, SIR President Charles E. Ray Jr., stated, “We appreciate CMS’ considerable effort in developing the proposed rule and believe that, with some modifications, a workable solution for patients and interventional radiologists can be achieved. Several aspects of the rule, as proposed, could have negative consequences for patients’ access to and choice of care.”
Dr. Ray continued, “We are concerned that the proposal’s arbitrary thresholds regarding who reports on all four aspects of the Quality Payment Program and the mechanisms and timelines for reporting may actually work against the intent of the Medicare Access and CHIP Reauthorization Act. Rather than providing increased access to innovative, quality care for all patients, the reporting burdens and restrictions may reduce access to care, particularly in rural and underserved areas.”
According to SIR, under the rule, physicians who fall below arbitrary thresholds comprised of total billed Medicare charges and total Medicare patients seen, or a yet-to-be defined list of patient-facing procedures, will either be excluded from MIPS or required to report on fewer MIPS measures. SIR believes a potential, unintended consequence of these low thresholds is that patient access to low-complexity but critical interventional radiology services in some practices will be limited, particularly in smaller groups and rural communities. These practices have historically used the group practice reporting option (GPRO) to simplify the administrative burden of measure reporting under current quality measurement system.
Dr. Ray stated, “The rules proposed for GPRO under MIPS take an all or nothing approach for reporting. We are concerned that there could be an impetus for groups whose physicians meet different thresholds to limit access to important patient-facing, interventional radiology services needed in the community simply because of the reporting requirements. This is not good for patients.”
SIR’s comment letter to CMS, which is available online here, provides details about each of the recommendations.
SIR recommended that CMS raise the threshold to 100 encounters, allow for mixed reporting within a mixed group, and offer a 2-year notice of change to allow clinicians the opportunity to adjust practice and reporting, given that there is a 2-year lag between performance and adjustment years.
In addition to having unintended consequences for patient’s access to an interventional radiologist’s care, SIR is also concerned that aspects of the rule make it difficult for interventional radiologists to accurately capture and measure quality across the breadth of care they provide.
SIR is recommending that CMS raise the cap on reporting measures contained in a single Qualified Clinical Data Registry (QCDR) and allow physicians to report across multiple QCDRs to measure quality. SIR believes this would incentivize a “team-based” approach to patient care and allow specialties like interventional radiology, which treat an array of conditions all over the body, to use a number of registries.
Dr. Ray explained, “To drive the best quality of care, physicians should be allowed to measure themselves against metrics specific to the procedures they’re performing. However, practitioners are currently limited to reporting through a single QCDR and that registry is capped to only 30 quality measures.”
In late 2016, SIR will launch its IR Registry within the American College of Radiology’s National Radiology Data Registry and CMS’s restrictions around QCDRs will make it difficult to cover the scope of interventional care in one registry.
Dr. Ray added, “Given the breadth and variety of practice within interventional radiology, our members need a sufficiently wide variety of measures from which to choose in order to meaningfully and accurately report on their performance. This flexibility of defining measures in a QCDR is complementary to the annual call for MIPS measures and would increase the likelihood that interventional radiologists would be able to report on quality measures meaningful to the Medicare patient population they treat.”