AAFP Urges CMS to Use Accurate Data, Pragmatic Reporting Requirements and Improved Meaningful Use Requirements in Upcoming Regulations

Tuesday, November 17, 2015

Leslie Champlin
Senior Public Relations Strategist
American Academy of Family Physicians
(800) 274-2237, Ext. 5224

LEAWOOD, Kan. — Use accurate and actionable data to determine physician payment, simplify reporting requirements and improve the meaningful use program. That’s the message in a recent response by the American Academy of Family Physicians to a request for information from the Centers for Medicare & Medicaid Services on implementing the Medicare Access and CHIP Reauthorization Act’s merit-based incentive payment system (MIPS) and alternative payment models.

Due today, AAFP’s response to the CMS request for information noted that MACRA “not only repealed the faulty sustainable growth rate formula, but also set our health care system on a path away from episodic, fee-for-service payments toward more comprehensive and value-based payment.”

CMS must shun the inaccurate relative value data currently used in the fee-for-service system as the agency implements MIPS and APM programs, according to Robert Wergin, AAFP board chair.

“Despite our strong support for MACRA, the AAFP remains very concerned that the MIPS and APM programs will be built upon the biased and inaccurate relative value data currently used in the fee-for-service system,” Wergin wrote to Andy Slavitt, acting CMS administrator. “We strongly recommend that more be done to ensure Medicare pays appropriately for primary care physician services in these new payment models rather than pays based on this biased actuarial data that further exacerbates the undervaluation of primary care services.”

Moreover, CMS must “streamline, harmonize and reduce the complexity of quality reporting” in the new payment models, Wergin said. Quality measures in MIPS and APM programs should move away from the Physician Quality Reporting System (PQRS), which relies too heavily on satisfying reporting requirements and not enough on the clinical service that improves the quality of care, he wrote. Instead, the AAFP strongly urged CMS to use the measures developed by the Core Measure Collaborative. This multi-stakeholder group was formed to promote a simplified and consistent measurement system that both public and private payers would use. The system reduces the total number of quality measures, refines them to ensure their appropriateness, and relates them to patient health.

“The AAFP supports reasonable and achievable quality improvement programs that promote continuous quality improvement and measure patient experiences,” Wergin wrote. “However, the AAFP opposes an approach that requires physicians to report on a complex set of measures that do not impact or influence the quality of care provided to patients. Unfortunately, the current PQRS program does not support true quality improvement. Instead, it focuses on making physicians comply with burdensome reporting criteria, using resources that could otherwise be spent on continuous and meaningful quality improvement activities. By placing an emphasis on satisfying reporting requirements to avoid penalties, current programs distract attention from the real goal -- providing high-quality health care to patients.”

Equally important, CMS must consider the set of services provided to patients rather than rely on a third-party certification to recognize practices as patient-centered medical homes within the APM model.

“We do not consider the PCMH tantamount to third-party recognition as a PCMH,” Wergin wrote. “The PCMH is a set of functions within a practice, not something granted by a third party. The AAFP encourages CMS to consider the Joint Principles of the Patient-Centered Medical Home and the key functions of the Comprehensive Primary Care Initiative(innovation.cms.gov) as criteria for determining what constitutes a PCMH. The Joint Principles, when aligned with the five key functions of the CPC initiative, capture the true definition of a PCMH and its performance thresholds.

“Furthermore, the AAFP proposes that payments for primary care services under this advanced primary care delivery model be made on a per-patient basis through the combination of a global payment for direct patient care services and a global care management fee.”

Among other recommendations, the AAFP called on CMS to rectify the “poorly designed meaningful use program and its lack of interoperability standards,” Wergin wrote. “Physicians face significant challenges with their electronic health records and meeting current meaningful use standards. Until the meaningful use program is improved and the EHR issues are resolved, it is difficult to foresee a large percentage of physicians -- particularly physicians in small and independent practices -- being successful in MACRA programs. EHRs should be a tool for success in a physician’s practice, not an obstacle to overcome.”

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Founded in 1947, the AAFP represents 136,700 physicians and medical students nationwide. It is the largest medical society devoted solely to primary care. Family physicians conduct approximately one in five office visits -- that’s 192 million visits annually or 48 percent more than the next most visited medical specialty. Today, family physicians provide more care for America’s underserved and rural populations than any other medical specialty. Family medicine’s cornerstone is an ongoing, personal patient-physician relationship focused on integrated care.  To learn more about the specialty of family medicine, the AAFP's positions on issues and clinical care, and for downloadable multi-media highlighting family medicine, visit www.aafp.org/media. For information about health care, health conditions and wellness, please visit the AAFP’s award-winning consumer website, www.familydoctor.org(familydoctor.org).