|AAOS Submits Comments on Quality Payment Program |
Last month, the AAOS submitted comments to CMS on the final rule for the Quality Payment Program. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) established the Quality Payment Program for eligible clinicians. Under the Quality Payment Program, eligible clinicians can participate via one of two tracks: Advanced Alternative Payment Models (APMs); or the Merit-based Incentive Payment System (MIPS). The Centers for Medicare & Medicaid Services (CMS) began implementing the Quality Payment Program through rulemaking for calendar year (CY) 2017. This final rule, released November of 2017, provides updates for the second and future years of the Quality Payment Program. Read more about the final rule in Advocacy Now online here: http://aaos.digital-enews.com/2017/advocacy_now/nov14/pages/article2.html.
In this comment opportunity, AAOS noted that the recent announcement of the “Patients Over Paperwork” Initiative “was a welcome harbinger of an end to regulatory overload.”
“The AAOS appreciates CMS’ efforts to reduce the burden on clinicians and to introduce greater flexibility,” the comments state. “November saw the release of 4196 pages of rulemaking, clearly demonstrating the level of complexity in the current payment programs. The AAOS implores CMS to act swiftly to simplify the QPP and other payment models.”
Regarding the MIPS track, AAOS expressed appreciation for the flexibilities offered to small practices and support for the increase in the low-volume threshold. The AAOS continues to advocate for voluntary, rather than mandatory, participation in all models. For that reason, the AAOS fully supports the opt-in policy for providers who don’t have to – but may want to – participate in MIPS. According to the AAOS comments, many providers expended resources in preparation for MIPS inclusion under the 2017 low-volume threshold. For these providers, an opt-in policy should be initiated as soon as possible. Moreover, AAOS encourages CMS to expand the opt-in policy to all providers, regardless of whether they meet either of the threshold criteria.
While CMS anticipates increased Advanced APM participation over the next several years, AAOS also noted that presently, opportunities for specialists remain an issue. In fact, the Track 1/Certified Electronic Health Record Technology (CEHRT) Comprehensive Care for Joint Replacement (CJR) model will begin in Performance Year 2018. This marks the first and only opportunity for Advanced APM participation for orthopaedic surgeons. AAOS looks forward to the next iteration of the BPCI model that will qualify as an Advanced APM. Further, AAOS still has concerns regarding the Qualifying Participant (QP) determination for these models.
“Currently, twenty-five percent of Medicare payments or twenty percent of Medicare beneficiaries must be paid through the APM to reach QP status,” the comments state. “In other words, nearly 1 in 5 patients would need to receive a joint replacement for an orthopaedic surgeon to be a QP for CJR. For Advanced APMs based on a procedural episode, such as CJR CEHRT Track, reaching QP status is exceedingly difficult. A provider attempting to gain QP status would likely have to restrict his or her practice to surgical patients, specifically to lower extremity joint replacements. This hyper-specialization would lead to a decrease in non-surgical orthopaedic access and, ultimately, due to delayed intervention, a greater incidence of joint replacement procedures. As the AAOS has requested in the past, specialist Advanced APMs should have a lower threshold for QP determination or alternate measure for participation.”
AAOS also further emphasized support for incentives for alternative payment arrangements under Medicare Advantage that qualify as Advanced APMs. Medicare Advantage has elements of an Advanced APM (e.g., financial risk, aligned goals, robust quality metrics) and rewards innovation over reporting. Participation in Medicare Advantage will create a more accessible entry to Advanced APMs.