AAFP Continues Rigorous Oversight of New Payment Model Details

Comments to CMS Focus on APMs, MIPS

December 20, 2016 04:00 pm News Staff

The AAFP continues to expend a tremendous amount of effort on behalf of family physicians to ensure their success in new payment models that are still undergoing scrutiny by stakeholders. The work is all related to CMS' new Quality Payment Program to be implemented as a result of the 2015 passage of the Medicare Access and CHIP Reauthorization Act.

The Academy is dedicated to staying involved in the rule-making process, so it's no surprise that the AAFP responded directly to CMS regarding the release of a final rule that will implement two new payment pathways for physicians in 2017 and beyond: alternative payment models (APMs) and the Merit-based Incentive Payment System (MIPS).

The final rule, left open for comments, was published in the Nov. 4 Federal Register.(www.gpo.gov)

The AAFP's Dec. 15 letter(47 page PDF) to CMS Acting Administrator Andy Slavitt, signed by AAFP Board Chair Wanda Filer, M.D., M.B.A., of York, Pa., provided extensive feedback on dozens of provisions in the rule that affect physicians and their patients.

Through its recommendations, the AAFP seeks to improve implementation of the MIPS and APM pathways to both increase physician participation and protect their clinical time with patients by eliminating administrative tasks associated with the programs.

The nearly 50 bullet points in the letter cover a lot of territory. For instance, the AAFP

Story Highlights
  • The AAFP continues its oversight of the details associated with new payment models related to CMS' Quality Payment Program.
  • In a letter to CMS, the AAFP provided extensive feedback on dozens of provisions in a recently released final rule that will implement alternative payment models and the Merit-based Incentive Payment System.
  • The AAFP seeks to simplify the implementation process to both improve physician participation and protect physicians' clinical time with patients.
  • encouraged CMS to take primary care and small practices into consideration as they design new APMs, as well as to release these models in a timely fashion;
  • insisted that virtual groups are a necessary component if small rural practices are to successfully participate in MIPS;
  • asserted that the quality reporting burden under MIPS should be equal for all participating physicians by 2018 and that any decrease in the number of quality measures should be applied across all specialties;
  • decried any effort to make family physicians accountable for the total cost of care;
  • called on CMS and the Office of the National Coordinator for Health IT to devote the resources needed to improve how certified electronic health record technology "supports and enhances clinical workflow," including assigning more accountability to vendors;
  • urged CMS to continue to back away from using health IT utilization measures after seeing the explosion of unintended consequences in the meaningful use program;
  • stated its continued opposition to CMS' use of financial risk and nominal risk standards in medical home models; and
  • recommended CMS make APM incentive payments directly to qualified professionals.

In addition, the AAFP expressed disappointment "that CMS does not feel confident enough in its abilities and the abilities of its contractors to commit to actually paying the APM incentive payments before the end of the payment year."

Regarding physician-focused payment models, the AAFP responded strongly to CMS' revised definition and noted that such models currently don't have to include any physicians at all.

"CMS will not require physician group practices or individual physicians to be included as APM entities, and they have expanded the list of ECs (eligible clinicians) to include a host of nonphysician providers," said the Academy.

The AAFP also pointed out that it recently created specific principles(2 page PDF) that support physician-led, patient-centered APMs.

"We believe that APMs must provide longitudinal and comprehensive coordinated care with the primary care team through agreements with primary care physicians if the APM is not already primary care-focused," said the AAFP. "The final CMS definition … seems to ignore both of these principles."

The Academy noted it had no objections to the "inclusion" of nonphysician eligible clinicians in physician-focused payment models, but it did object to CMS shifting the focus away from physicians -- especially primary care physicians -- to favor nonphysician eligible clinicians.

"From our perspective, 'physician-focused' means exactly that -- it should be focused on physicians" as leaders of the health care team, said the AAFP, noting that it is inappropriate "to consider models that do not satisfy this basic requirement."

Furthermore, according to the AAFP's newly inked principles, APMs should

  • coordinate with the primary care team,
  • promote evidence-based care and
  • exhibit a multipayer design.

"We ask that CMS consider these principles when considering criteria for physician-focused payment models in the future to ensure that patient-centered, longitudinal and comprehensive care is being promoted across providers and care settings," the AAFP concluded.

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