The American Society of Anesthesiologists (ASA) recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) related to the 2018 Quality Payment Program (QPP) Proposed Rule. The goal of their 28-page letter, according to a prepared statement by the ASA, is to ensure “physician anesthesiologists have ample opportunities to meaningfully participate and succeed in either the Merit-based Incentive Payments System (MIPS) or Advanced Alternative Payment Models (APMs) pathways under the QPP.”
The letter included more than 40 comments and recommendations, most related to MIPS. The following are some of the most notable, divided by category.
- Approve 2018 QCDRs and their measure specifications by December 1, 2017, in order to accommodate a 12-month reporting period.
- Require QCDRs to post their measure specifications on a public website so that participants can more easily evaluate which reporting option to choose.
MIPS Quality Performance Category
- Allow the voluntary use of facility-based measures as a proxy for the Quality performance category for hospital-based eligible clinicians.
- Include A.5 Prevention of Post-Operative Vomiting (POV) – Combination Therapy (Pediatrics) in the Anesthesiology Specialty Measure Set as proposed.
- Include measures in the Anesthesiology Specialty Measure Set only when the denominator set is solely composed of anesthesia service codes (00100-01999), which means not including or removing the following measures:
- 226 Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention;
- 402 Tobacco Use and Help with Quitting Among Adolescents in the Anesthesiology Specialty Measure Set;
- 317 Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented from the Anesthesiology Specialty Measure Set; and
- 130 Documentation of Current Medications in the Medical Record.
- Remove topped out measures only if doing so does not disproportionately disadvantage certain specialties, and incorporate new measures in such a way “that removal of topped out measures does not aggravate inadequacy of available measures.”
- Consider the maintenance of high levels of performance to be just as favorable as improvements from lower to high levels in Quality scoring.
MIPS Advancing Care Information Performance Category
- For clinicians who do not have ACI scores (because of special status), substitute a score with a 50 percent base and the clinician’s Quality score (adjusted to a 50-100 scale) for the ACI performance score instead of zeroing the ACI score and expanding the Quality or Quality and IA scores.
MIPS Cost Performance Category
- Allow the voluntary use of facility-based measures as a proxy for the Cost performance category for hospital-based eligible clinicians.
- Remove positive and negative payment adjustments from previous years payment calculations, along with geographic and other adjustments that do not reflect the utilization and intensity of services, when calculating Cost performance category scores so that providers are not unfairly penalized or rewarded in subsequent years.
- Develop an alternative cost measurement approach for non-patient facing MIPS eligible clinicians before rolling out the Cost performance category with a 10 percent weighting for 2018 or a 30 percent weighting in 2019. “We believe it is premature to include the Cost performance category measures in the MIPS total score,” the ASA said. “We urge CMS to address these issues in any rollout of data on costs to eligible clinicians. Additionally, cost measures should be tested and validated prior to their implementation in a fashion that limits risk for eligible clinicians.”
MIPS Improvement Activities Performance Category
- Expand policy of doubling IA score for hospital-based clinicians as it currently does for non-patient facing clinicians.
- Include ASA’s Perioperative Surgical Home (PSH) IAs, PSH Care Coordination and PSH Population Management Strategies, as proposed. “With both these activities proposed for MIPS, a clinician participating in a PSH pilot has the ability to receive half his/her reporting requirements for the IA component,” the ASA explained
CMS receives comments from many stakeholders, and they may or may not finalize these changes. When the final rule is released, we will detail relevant changes for readers. For more information about the proposed rule or the ASA’s comments, review the following resources:
- ASA’s announcement about their comments and link to the full letter
- The Proposed Rule for CY 2018 Updates to the Quality Payment Program
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