This week CMS offered a glimpse at a possible replacement for Medicare's fee-for-service physician reimbursement system, and so far, there are far more questions than answers about what physicians can expect.
Fifty-five questions to be precise, according to an "issues paper" that accompanied Tuesday's six-hour public listening session on developing a transition plan. CMS knows that it wants a value-based purchasing system—the Medicare Improvements for Patients and Providers Act, which averted a 10.6% payment cut this summer, mandated it—but the organization doesn't yet know what it will look like or how to get there.
As Bill Woodson, senior vice president with Sg2, puts it, "an 'issues paper' is a way for the policy establishment to throw up their hands and say 'What in the world have we gotten ourselves into here and does anyone have any Pepcid?'"
So for now, CMS is soliciting public feedback.
Here's what we know: The primary focus will be performance-based payment, and the plan will accommodate all practice settings. Whatever CMS comes up with must be budget-neutral across Medicare Parts A and B, and it will also likely attempt to accelerate the adoption of EHRs and e-prescribing. For guidance, CMS will look to its efforts with Physician Quality Reporting Initiative and other pay-for-performance demonstration projects.
But which quality measures should be used to measure performance? Who should be the accountable entity—the individual, group practice, or the broader care system? How should accountability be enforced? How large does the payment incentive need to be to achieve the goal?
These are some big-picture questions, and they are only a handful of the questions CMS included in the issues paper.
I only caught a small portion of Tuesday's session (did I mention it was six hours long?), but it won't be the last opportunity for comment. MIPPA mandates the submission of a plan for transition to a value-based purchasing system to Congress by May 1, 2010.
That seems like a long time, but there are a lot of questions to answer between now and then, and it's important that physicians are active participants in the process. Comments can be e-mailed to CMS or mailed or faxed using the information in the Federal Register. It's tough to find time, particularly six hours on a Tuesday afternoon, when juggling clinical and administrative obligations. But that's where physician associations and other representatives can help.
I don't know of many physicians who are happy with the current fee-for-service system, and now there's an opportunity to shape its replacement. This is what you've been waiting for. Make sure your voice is heard.