On behalf of more than 1,300 gastroenterologists and other physician specialists whose independent GI practices are members of the Digestive Health Physicians Association, DHPA submitted comments to the Centers for Medicare & Medicaid Services responding to CMS’s request for information regarding implementation of the Merit-Based Incentive Payment System, promotion of Alternative Payment Models, and Incentive Payment for Participation in Eligible Payment Models. DHPA’s comments focused on topics of particular importance to independent gastroenterology practices:
- The need to create quality metrics, resource use policy, and clinical practice improvement categories that acknowledge the unique circumstances of specialists such as gastroenterologists furnishing acre in the independent practice setting.
- The importance of incentivizing independent practices to exercise more effective and efficient control over a patient’s care, even when this care is provided “downstream” of the provider, and providing better reporting to support this management.
- Aligning the requirements of the Qualified Registry and Qualified Clinical Data Registry reporting system to provide maximum flexibility to reporting Merit-Based Incentive Payment System (MIPS) eligible professionals.
- Defining and implementing Physician-Focused Payment Models (PFPMs) broadly to allow independent specialty practices to participate in their own right, without consolidation with hospitals.
- Allowing substantial opportunities for independent specialists to comment and provide feedback as CMS implements the massive changes required by the MIPS and PFPMs.