AAFP Calls for Further Changes to QPP Interim Final Rule

December 21, 2017 03:52 pm News Staff

The AAFP continues to provide solid input to the federal government on implementation of the Quality Payment Program (QPP). The latest example is a Dec. 19 letter(15 page PDF) to CMS Administrator Seema Verma with suggestions on how the agency can improve the QPP interim final rule that was published in the Nov. 16 Federal Register.(www.gpo.gov)

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The letter, signed by AAFP Board Chair John Meigs, M.D., of Centreville, Ala., noted that the Academy's recommendations are meant to "continue to strengthen primary care for Medicare beneficiaries, to enable more physicians to participate in Advanced Alternative Payment Models (AAPMs), and to further reduce the administrative and regulatory burdens family physicians face in the Merit-based Incentive Payment System (MIPS)."

The AAFP relayed its support for portions of the QPP and suggestions for improving other sections by

  • expressing support for an opt-in pathway for family physicians and other MIPS-eligible clinicians who fall below the agency's low-volume threshold;
  • suggesting it would be "both beneficial and logical" if physicians in similar practices who are part of a larger multispecialty group reported quality as a smaller subgroup;
  • asking CMS to ensure there is parity in quality reporting by insisting all eligible clinicians submit data on six measures using cross-cutting measures if necessary;
  • opposing use of certain measures in the QPP -- specifically, Medicare spending per beneficiary and total per capita cost -- because those two measures were intended for use at the tax identification level and may not be valid at the solo/small practice level;
  • requesting that CMS hold physicians harmless in the cost category if they cannot be "reliably measured against at least one episode-based cost measure" and do so at least until CMS can create a "more even and meaningful playing field;"
  • reiterating concerns about complex scoring in the MIPS performance categories;
  • supporting CMS' exemption of alternative payment model entities enrolled in round one of the Comprehensive Primary Care Plus program from the Medical Home Model-eligible clinician limit, and urging the agency to extend the exemption across the board;
  • agreeing with CMS' suggested definition of "Other Payer Medical Home Model" and suggesting ways to strengthen the primary care emphasis;
  • calling on CMS to make payers responsible for submitting relevant information on payer arrangements;
  • giving full support to the Physician-Focused Payment Model Technical Advisory Committee's role in evaluating physician-focused payment models; and
  • remaining in full support of CMS' plan to establish a policy for extreme and uncontrollable circumstance policies for the MIPS performance categories without requiring clinicians to submit an application.

The 15-page comment letter goes into detail about each of these items.

The AAFP offered to further discuss its suggestions and applauded steps taken by CMS in the interim rule to increase the probability that family physicians will find success in CMS' payment reform programs.

Family physicians who want to offer their individual suggestions to CMS regarding the QPP final interim rule have until Jan. 2 to do so. The easiest way is by electronic submission.(www.regulations.gov)  

Related AAFP News Coverage
Quality Payment Program Interim Final Rule
Glean Key Points on 2018 QPP From AAFP Executive Summary


AAFP Urges Changes in 2018 Quality Payment Program Proposal
MIPS Performance Period, Measures, Cost Weighting Among Top Concerns


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