In May, a group of national medical specialty societies provided input to federal lawmakers and regulators on steps to improve the Medicare Quality Payment Program (QPP). In a document released to U.S. Members of Congress and to administrators with the U.S. Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS), the societies outlined several areas where lawmakers and regulators could improve the current Medicare QPP. The QPP is intended to provided payment and incentives to healthcare providers for improving quality and value to patients.

Among the recommendations were updates to the Merit-based Incentive Payment System (MIPS) under QPP and the Alternative Payment Model (APM) system under QPP.

For MIPS, recommendations included:

• Provide scoring flexibility to CMS to allow for multi-category credit to reduce silos between each of the four MIPS categories.
• Provide flexibility to CMS to set multiple performance thresholds
• Update the Promoting Interoperability performance category as doctors should be allowed to use certified EHR technology (CEHRT), technology that interacts with CEHRT to be considered a meaningful user, or a qualified clinical data registry to participate in PI.
• Improve the cost performance category to allow CMS to prioritize cost measures that are valid and actionable. CMS should focus on episodes of care with high variability and potential high impact for change.
• Align comparisons in the MIPS Quality performance category and Physician Compare program
• Incentivize new measures and ensure stability for existing measures

For APMs, recommended actions included:

• Extend APM incentive payments as there currently are very limited opportunities to move from MIPS into an APM, and because the APM pathway under MACRA has not been very robust, few physicians have qualified as APM participants.
• Qualified APM Participant (QP) threshold flexibility
• Adjust multi-payer QP thresholds
• Mitigate APM overlap issues
• Exclude revenues from Part B drugs
• Expand access to medical homes

These actions together are recommended to achieve the goals of the original MACRA legislation to better align payment policies with quality care and improved patient reported outcomes.

Read Full Set of Recommended Actions here: MACRA Improvements 2019

UPDATE: Subsequent to the submission of recommended actions, a coalition of medical specialty societies, including ISASS, submitted a formal letter to both house of the U.S. Congress.  The letter spelled out the recommended actions and asked Congress to take up legislation to accomplish the improvements and updates.

Read Letter here: 2019-5-23 MACRA Federation Sign-on Letter FINAL