January 22, 2018 09:10 am News Staff – The Medicare Payment Advisory Commission (MedPAC) recently recommended that the Merit-based Incentive Payment System (MIPS) be replaced with a proposed program that would be less burdensome and more likely to improve quality.
The commission voted during its Jan. 11-12 meeting to recommend replacing MIPS -- one of two tracks in CMS' Quality Payment Program -- with a proposed Voluntary Value Program (VVP).
Commissioners said MIPS is too flawed to achieve CMS' goals of reducing overall costs and improving patient care.
"We came to the conclusion that, no, it's simply not fixable for the reasons of cost, the reporting requirements, the burden on practicing physicians, the fact that it was very likely that the quality data was not going to be relevant and salient and useful," said MedPAC Chair Francis "Jay" Crosson, M.D.
Commissioners were concerned that because MIPS allows physicians to select the quality measures they want to be graded on, there is little basis for data comparison and the system encourages selection of measures where high scores can be achieved.
"It's not going to improve quality, and it's not going to improve value. It's an incredible burden for physicians," said Commissioner Rita Redberg, M.D., M.Sc. " I think we all want to achieve value, and this is just not going to do it."
The VVP, on the other hand, would rate practices on measures that include clinical quality, patient experience and value using data that CMS already possesses, which would reduce the reporting burden on physicians. It could conceivably be implemented by 2020 as a transition phase for physicians before they are ready to move into a more advanced payment program.
The program would incorporate virtual groups, such as physicians who practice at the same hospital or who are members of the same local medical society.
Some commissioners also wanted to ensure that any new payment model would help physicians who care for patients with greater medical needs move into a more advanced payment model.
"We want to be sure that those who are serving more socioeconomically disadvantaged populations are not going to end up hurt by this, so we would consider a model in which those who come together voluntarily and serve such a population might actually get a higher payout," said Commissioner Dana Gelb Safran, Sc.D.
The commission, which is charged with making policy recommendations to legislators, acknowledged that substantial details need to be worked out before the VVP could be presented to Congress.
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Federal officials should promote payment methods that boost competition in the marketplace and create greater choice for patients. Mergers among hospitals in a single market increase costs for patients and drive up prices for low-value medical services.
"We strongly believe that this is an area where greater competition would benefit patients, physicians, and other health care providers," the letter stated. "Allowing hospitals and health systems to expand their stranglehold on the marketplace is harmful for patients, physicians, employers, and federal and state health care programs."
When a small number of commercial carriers dominate specific geographic markets, they exert inordinate power over consumer choice and payment. For example, Medicare Advantage plans now cover 19 million beneficiaries, yet just two insurers account for 41 percent of this market. On a similar note, Blue Cross Blue Shield accounts for 85 percent of the individual market and 93 percent of the large group market in Alabama.
When large health systems merge, they often shrink their networks, meaning patients may be forced to go out of network to maintain a relationship with their physician. For physicians, greater consolidation means they are often pressured to accept lower payment levels to stay within a particular network.
"The AAFP is deeply troubled by the explosion of mergers between hospitals and health systems," said the letter. "These mergers, in our opinion, are driving up costs, decreasing competition, and creating an escalating arms race in medical technology and costly, low-value medical services. No evidence exists that these mergers are decreasing prices in those marketplaces where they occur."
Another trend that limits access is the rapid rise in high-deductible health plans that dominate the employer-sponsored insurance market. Individuals with these plans often have annual deductibles of $2,000 or more and, as a result, may delay or forgo care rather than pay for a primary care visit out-of-pocket.
"Higher deductibles create a financial disconnect between individuals, their primary care physician, and the broader health care system," the letter noted.
The AAFP has proposed a primary care benefit that would be standard for all commercial policies under which visits to a primary care physician or medical team would not be subject to a deductible or copayment.
Finally, the letter presses the agency to remove legal barriers for patients who want to use their health savings accounts to pay for direct primary care (DPC) arrangements. Current tax law prevents patients from doing so because the IRS considers DPC to be insurance. The AAFP has supported legislation previously introduced in Congress that would change that designation.