CMS must do more to improve the accuracy of Medicare physician payments.
That was the urgent message delivered via a Dec. 16 letter(2 page PDF) from AAFP Board Chair Robert Wergin, M.D., of Milford, Neb., to CMS Acting Administrator Andy Slavitt.
The intent of the letter was to spur the agency to act on recommendations made by the U.S. Government Accountability Office (GAO) in its report(www.gao.gov) titled Medicare Physician Payment Rates: Better Data and Greater Transparency Could Improve Accuracy.
The report, which called for a greater voice for primary care, was published on May 21 and delivered to specific congressional committees for review.
More than six months have passed since then, and it's not clear to the Academy that much has changed.
- In a recent letter to CMS, the Academy urged CMS to act on recommendations offered in a Government Accountability Office (GAO) report that would improve Medicare payment to primary care physicians.
- The GAO report, released in May, was critical of the process by which physician services are valued, especially some elements of the AMA/Specialty Society Relative Value Scale Update Committee (RUC) that introduce bias into the system.
- AAFP Board Chair Robert Wergin, M.D., stressed the need for quick action so that new payment models currently under construction won't be based on the same flawed RUC data.
"We want to learn what steps CMS has taken so far and what actions the agency is planning to take to implement the recommendations in this report," said Wergin.
The Academy also must know what other actions CMS plans to take "to improve the accuracy of Medicare payments for primary care services," he added.
The GAO report acknowledged that the AMA/Specialty Society Relative Value Scale Update Committee (RUC) "has a process in place to regularly review Medicare physicians' services' work relative values."
Those values reflect the time and intensity required to perform a service. However, pointed out GAO report authors, recommendations made by the RUC to CMS "may not be accurate due to process- and data-related weaknesses."
Wergin's letter reflected the Academy's sense of urgency about the situation and pointed to payment models currently in development.
"Despite the AAFP's support for the Medicare Access and CHIP Reauthorization Act(53 page PDF) (MACRA), we remain worried that CMS will build the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM) programs upon the existing biased and inaccurate relative value data currently used in the fee-for-service system," said Wergin.
He said such action would be "a terrible mistake" and cautioned that relying on the status quo would slow the transformation of the U.S. health care system from a historically fee-for-service model to a system built on value-based payment.
MACRA will be implemented incrementally during the next few years, said Wergin. Therefore, it is imperative that the MIPS and APM programs are based on accurate data rather than "the inaccurate and outdated resource-based relative value scale established in 1992."
Wergin directed CMS to take "immediate steps" to ensure that Medicare payment for primary care physicians' services would be valued appropriately in the new payment models.
To that end, he urged CMS to
- increase the value of primary care services in the Medicare system,
- disregard RUC data derived from limited and statistically insignificant physician survey responses,
- use funds already appropriated to CMS to collect data on physician services to assist in determining relative value units,
- create an adjunct committee to the RUC that would include stakeholders other than physicians, and
- aim for transparency in that committee's activities.
Furthermore, if funding is lacking to create a public committee, CMS must request such funding from Congress, said Wergin.
He reminded CMS of the AAFP's ongoing commitment to assist CMS in developing "accurate payment policies" and pointed out that the Academy's focus was on "improving the quality and accuracy of the data used by the RUC and, by extension, CMS."
CMS must address the problems, said Wergin, because "the quality of the current (RUC) data produces inequitable values for physician services."
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Medicare Access and CHIP Reauthorization Act of 2015