Quality Payment Program implementation

AGA position: Quality Payment Program (QPP) implementation must be monitored to ensure the intent of the law is realized.

The Medicare Access and CHIP Reauthorization Act (MACRA) signed into law in April 2015, replaced the flawed sustainable growth rate (SGR) formula with the Quality Payment Program (QPP). The QPP provides a new approach to paying providers for the value and quality of their care. The QPP is comprised of two tracks the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). The Centers for Medicare & Medicaid Services (CMS) began implementing the QPP on Jan. 1, 2017.

QPP implementation changes

AGA appreciates that CMS has designated 2017 and 2018 as transition years to allow providers to learn about the QPP and to gradually increase their preparedness for MIPS. In the first two years, CMS has provided physicians with significant flexibility and greater opportunity to succeed under the new program. CMS’ transition policies reflect the concerns that have been expressed by AGA, the broader physician community and Congress.

Congress also recently acted to provide CMS additional flexibility with respect to QPP and MIPS implementation, including:

  • Excluding Medicare Part B drug costs from MIPS payment adjustments.
  • Eliminating improvement scoring for the cost performance category for the second through fifth years of MIPS.
  • Allowing CMS to weight the cost performance category at less than 30 percent, but not less than 10 percent for the second through fifth years of MIPS.
  • Allowing CMS flexibility in setting the performance threshold for MIPS in years two through five to ensure a gradual and incremental transition to the performance threshold set at the mean or median for the sixth year.

 

Congress also expanded the scope of the Physician Focused Payment Model Technical Advisory Committee (PTAC) such that the committee may now provide feedback and technical assistance on alternative payment models.

Together, these changes and CMS’ transition policies will help better transition physicians to the QPP. Since most gastroenterologists will participate in MIPS, AGA has argued that these changes were essential to ensure that the program will work and allow for physicians to be successful in their participation.

Gastroenterology develops innovative payment models

Gastroenterologists have been at the cutting edge of payment and delivery reform. As a community, we have worked with payors and other providers — both primary care and specialists — to develop innovative tools to improve quality of care and reduce costs. These efforts involve bundled payment initiatives for common gastroenterology procedures and conditions, such as colonoscopy and obesity, as well as episodic payment for gastroesophageal reflux disease. These initiatives have the potential to benefit both private payors and the Medicare program, if CMS increases flexibility for new payment models.

Given the work that AGA has already invested and the expertise that we bring to the table, CMS should ensure that APMs and physician-focused payment models provide substantial opportunities for gastroenterologists. Without the inclusion of specialty models, payment reform is likely to be unsuccessful and will exclude the highest cost, most complicated patients.

Call to action: QPP implementation needs to recognize value of specialty care.

AGA appreciates the flexibility that CMS has provided to physicians to help ease the transition to the QPP. We believe these flexibilities will help physicians to successfully comply with the new requirements under the QPP. AGA also appreciates that Congress has acted to provide CMS with additional flexibility while implementing the QPP. AGA asks Congress and CMS to continue to implement the QPP in a way that maximizes flexibility and success. 

MACRA encourages the development of specialty-specific Physician-Focused Payment Models (PFPMs). However, the review criteria employed by the PTAC does not encourage specialty-focused models. Moreover, although recent changes from Congress expand PTAC’s role, it’s unclear how these changes will impact the development of specialty-focused PFPMs. AGA asks Congress to closely monitor the PTAC review process to ensure the advancement of specialty-focused PFPMs, as was intended under the law.

Reviewed: April 2018