DHPA has filed comments in response to CMS’s CY 2018 Updates to the Quality Payment Program (“QPP”) Proposed Rule. In its comment letter, DHPA provided three specific suggestions for CMS to consider incorporating into the Final Rule to ensure Medicare beneficiaries’ continued access to critically important drug treatments and to facilitate greater participation by independent gastroenterology practices in payment systems mandated by MACRA.
First, DHPA urged CMS to protect patient access to Medicare Part B drugs administered in the physician office by not applying MIPS payment adjustments to the actual cost of Part B drugs. At a minimum, DHPA requested that CMS delay doing so until this purported “clarification” in the application of MIPS payment adjustments can be reevaluated as part of the notice-and comment rulemaking process for the CY 2019 QPP. Under the Proposed Rule, physicians would risk administering Part B drugs at a loss, especially when larger negative payment adjustments are applied in later years. DHPA argued that this would pose a direct threat to patient care and should not be implemented without CMS issuing a formal proposal and soliciting comment from stakeholders.
Second, DHPA requested that CMS expand the authority of the Physician-Focused Payment Model Technical Advisory Committee (PTAC) to approve Physician-Focused Payment Models (PFPMs) as a means of reducing the substantial backlog of Alternative Payment Model (APM) proposals in front of PTAC and CMS. DHPA also requested that CMS take the following steps to bolster the process for development and implementation of PFPMs:
- Commit to a 90-day period for PTAC to review and decide whether to approve a proposed PFPM as an Advanced APM or MIPS APM, and to approve a certain number of PTAC-proposed PFPMs as Advanced APMs each year;
- Provide clinicians with clearer guidance in their development of PFPM proposals by publishing relevant, objective benchmarks that will be used by PTAC and CMMI to approve submitted models; and
- Apply a rebuttable presumption that, at a minimum, CMS will adopt any PFPMs approved by PTAC as MIPS APMs.
Lastly, DHPA commended CMS for its proposals to create greater flexibility for MIPS reporting at the virtual-group level and requested that CMS finalize the proposals with respect to “virtual groups” as a mechanism of encouraging specialty practices to participate in MIPS. DHPA also urged CMS to seek additional statutory authority from Congress to permit MIPS reporting at the virtual-group level not merely for group practices with 10 or fewer physicians (as MACRA currently allows), but for all groups practices regardless of size.
DHPA looks forward to working with CMS to continue the transition to the delivery and payment systems created by MACRA in a way that promotes and protects the high quality, cost-efficient care that gastroenterologists and other physician specialists furnish to Medicare beneficiaries in the independent practice setting.
Click here to read the full comment letter.