Although CMS sought to improve flexibility and simplicity for physicians, a physician advocacy group says the results are mixed and that more work needs to be done.
The Medicare Quality Payment Program final regulation for 2018 is getting mixed reviews from the Physicians Advocacy Institute.
In what could prove to be time-consuming nightmare, the 2018 reporting year will require physicians to submit a full 12 months of data, instead of the three months required in 2017, according to PAI board member Matthew Katz, who is also CEO of the Connecticut State Medical Society.
Katz spoke with HealthLeaders Media about the rules change. The following is a lightly edited transcript.
HLM: What do you like about the final rule for 2018?
Katz: Let’s put aside whether we like the program itself. When it comes to the changes that came in, PAI appreciates the addition of some exemptions for the smaller practices. This final rule expanded those exemptions to cover more small practices; those that have low volumes of Medicare patients, or low dollar amounts when it comes to the amount of care they provide for Medicare beneficiaries.
It does not punish physicians who are stuck with electronic medical records vendors who have not been able to update their programs. CMS’s previous approach was going to be you had to be 2015 CEHRT certified. A lot of smaller practices purchased EMRs a few years ago with the understanding that those EMR companies were going to update their systems. They never did. The doctors were going to be punished if CMS didn’t make some changes. So, they’re allowing the 2014 or 2015 CEHRT, and giving bonuses for 2015 because it doesn’t punish doctors whose EMR vendors have not been able to adhere to the requirements.
Virtual Workshop: Practical Training in Value-Based Care Delivery Under MACRA
There is also some progress in the episode-based measures they’ve come up with. We would like to see that expanded. They are providing some additional bonuses to small practices, which is good. And, they are focusing more on complex patients and providing bonuses for better care for dual-eligible patients. We think that is good.
Another thing we liked, the penalties for PQRS that were in place a few years ago, and the value modifier that were hitting doctors this year were going to be 4% and 2% in reductions. CMS did change that and make it 2% and 1% reductions, recognizing that some of the requirements may not have been the most sufficient for analyzing and having physician reports.
However, they still issued the penalties and are issuing them on Jan. 1. So, doctors will see a loss in revenues from Medicare as a result of those previous programs.
HLM: So, what’s the bad news?
Katz: It’s disappointing that, even though it is not ready for prime time, they are rolling out a cost component. No, it’s not 20% or 30% as originally envisioned, it is 10% of a physician’s score, which impacts them significantly. Even though it is not a tried-and-tested system that Medicare is rolling out for evaluating costs, they are going to make it count toward a physician’s score, which affects their payments, or lack thereof. That is problematic.
Also, some of these bonuses for small practices are good, but they aren’t going to kick in until the 2020 payment year. No one is getting them for a while.
HLM: PAI has raised concerns about new reporting requirements. Why?
Katz: A big problem we have is that in 2017 physicians only had to track quality for three months. We anticipated that CMS would continue that because they haven’t been able to tell doctors if the three months of data reporting was good, bad or indifferent. We were hoping that they were going to allow just three months in 2018. But, they are requiring a full year of quality reporting, starting Jan. 1, which gives a lot of practices less than two months, and many practices that hadn’t even started reporting for this year, a short period of time to figure out how they are going to report for next year.
HLM: Beyond the time crunch, why is this a problem?
Katz: Those practices that are reporting from this year won’t even know what CMS has valued their reporting at, good, bad or indifferent, until after they’ve started to collect. It could be six to eight months before they know. If they’re doing something wrong now they’ll be doing it wrong next year and they won’t know until the end of the year. So, we were hoping for more flexibility on the reporting time frame. We didn’t get it.
They are now requiring reporting as of Jan. 1. There is no time to reflect. No time to evaluate, and therefore no time to improve if the quality reporting itself is bad, let alone if the quality it’s purporting to measure is bad. With the reporting, you need to know if you’re doing it right. It you’ve got garbage coming in you’re going to have garbage coming out. Now they’re asking for that same garbage before they’ve evaluated it.
CMS should be rewarding those providers who are providing you with data, improving quality and reducing costs. If it’s just a reporting game in a timeframe, then no one is going to be focused on the quality improvements or cost reductions. They’re just going to focus on getting information, whatever it looks like, and however they can get it to CMS to meet those time frames.
HLM: Is there any chance that CMS will tweak this rule as 2018 unfolds?
Katz: Technically, this is the final that can’t be changed. They provide some additional comment period, and over the years CMS has made some last-minute adjustments on various components of other programs when they’ve recognized that something needed to change.
They also said that they are not finished with some parts of this when it comes to the flexibility. So, they will be putting more out.
John Commins is a content specialist and online news editor for HealthLeaders, a Simplify Compliance brand.