Failing to execute full MACRA implementation by excluding over half of providers is impeding the transition to value-based care, the industry group told Congress.
AMGA is urging Congress to enforce MACRA implementation as policymakers intended by no longer excluding providers from the Merit-Based Payment Incentive Program (MIPS).
“MIPS was designed as a viable transition tool to value-based payment in the Medicare program, where providers would be rewarded for their investments in health information technology (IT), care management processes, and people,” AMGA President and CEO Jerry Penso, MD, MBA, recently wrote to Speaker of the House Nancy Pelosi. “However, the Centers for Medicare & Medicaid Services (CMS) has not implemented MIPS as Congress intended.”
CMS has excluded more than one-half of providers (60 percent) from MIPS requirements in the past few MACRA implementation rules despite the original statute’s intentions to increase MIPS participation.
While the federal agency intended for the MIPS exclusions to ease providers into MACRA, the medical group association argued that the exclusions actually penalized high-performers. MIPS is a budget neutral program, so exclusions from the program resulted in lower payment adjustments for eligible clinicians who exceeded performance standards.
For example, the original MACRA statute called for a maximum +4 percent payment adjustment for MIPS high-performers in 2019. However, in reality, high-performers only received an aggregate payment adjustment of +1.1 percent in 2019 because of how MIPS exclusions impacted budget-neutrality.
Similarly, CMS anticipates lower payment adjustments for high-performers in later years. The federal agency projects a +1.5 percent adjustment in 2020, compared to a potential +5 percent adjustment in the statute. In 2021, CMS expects a +2 percent adjustment for high-performers, compared to the potential +7 percent adjustment in the statute.
“These insignificant payment updates fail to reward providers for superior performance in the MIPS program and provides nominal return on investments,” AMGA argued. “Unfortunately, MIPS has devolved into an expensive regulatory compliance exercise with little to no impact on quality or cost. Policymakers should no longer exclude providers from MIPS.”
More eligible clinicians should also be participating in MACRA’s Advanced Alternative Payment Model (APM) track to bolster value-based care, AMGA told policymakers. However, current APM revenue thresholds are preventing clinicians from transitioning to the pathway.
Eligible clinicians must have either a certain number of Medicare beneficiaries or a certain percentage of their Medicare revenue tied to the APM to qualify as an Advanced APM participant.
The revenue threshold in 2019 was 25 percent of a provider’s Medicare revenue under the APM. But CMS expects to increase the revenue threshold as the agency continues with MACRA implementation.
The revenue threshold is slated to increase to 50 percent of revenue by 2021 and 75 percent of revenue by 2023.
However, AMGA contended that the revenue thresholds are unlikely to be met by providers and the higher thresholds will dissuade providers from participating in the track.
“This is due to a dearth of commercial risk products and limited Medicare Advance APM options. Congress must eliminate these arbitrary thresholds so that more providers can make the transition to value as envisioned under MACRA,” the group wrote.
To promote greater MACRA participation, AMGA also called on policymakers to support data utilization. AMGA risk-readiness surveys have shown claims data access and data standardization are major obstacles to value-based care and MACRA implementation for providers.
Congress should require federal and private payers to provide access to all administrative claims data to providers in value-based arrangements, as well as standardize data submission and reporting processes, the association advised.
Additionally, the AMGA identified several regulatory challenges to value-based care that Congress should prioritize to effectively move providers away from fee-for-service. Among the regulatory recommendations are:
- Standardize quality measures used in value-based arrangements and prioritize outcomes-based measures
- Suspend the Stage 3 Meaningful Use requirement
- Allow hospitals to provide preferred post-acute care provider lists to patients being discharged
- Update the physician self-referral law to enable providers to form partnerships under value-based models
- Expand telehealth reimbursement in the Medicare Advantage patient population and waive geographic limitations for telehealth use for providers in value-based arrangements
- Waive the qualifying inpatient stay requirement for discharging to skilled nursing facilities and implement policies that permit providers to work with patient to provide services in the most clinically appropriate setting
“We’re well past the time for looking at value-based care as a concept,” stated Penso in a press release. “Now, it’s time to work to implement policies and incentives to aid providers who have invested in the staff and technology needed to deliver care in these new, value-based models. The legislative priorities and recommendations we’ve outlined for Congress today indicate AMGA’s and our members’ commitment to this needed transition.”