Changes Essential to Facilitate Meaningful Rheumatology Participation
On June 27, the Coalition of State Rheumatology Organizations submitted formal comments to the Centers for Medicare and Medicaid Services to register our concerns with its proposed Quality Payment Program (QPP).
The Quality Payment Program represents a new, more streamlined approach to paying physicians for the value of health care delivery, rather than the volume of services rendered, through the Merit-Based Incentive Payment System (MIPS) and alternative payment models (APMs).
CSRO emphasized to CMS the unique challenges rheumatologists face in these new programs and we seek modifications that will enable more meaningful engagement.
CSRO opposed the CMS proposal to replace the Rheumatoid Arthritis Measures Group (a set of eight quality measures reported as a group in the current Physician Quality Reporting System (PQRS) program), with a new specialty measure set that combines five of the rheumatoid arthritis quality measures with several allergy and immunology quality measures planned for use in the new MIPS.
We argued that the measures group was designed to look at rheumatoid arthritis in a more meaningful and comprehensive way, where each measure had a relationship with the other measures in the group. This is particularly important as rheumatoid arthritis is one of the most significant conditions rheumatologists diagnose, treat and manage in the Medicare population.
Removing the rheumatoid arthritis measures group greatly diminishes the value of the individual measures CMS proposes to retain as stand-alone measures or as part of the newly proposed Allergy/Immunology/Rheumatology specialty measure set, and requested that the RA Measures Group be maintained for purposes of the quality performance category in the MIPS.
We have long-registered concerns about resource use measures included in CMS’ existing Value-Based Payment Modifier (VM) program, which do not adequately consider the cost of pharmaceutical therapy in evaluating resource use. Unfortunately, CMS proposed to retain these measures, as well as incorporate two new cost measures focused on rheumatoid and osteoporosis, in the resource use performance category of MIPS, which represents 10 percent of the total MIPS composite performance score.
The current cost measures used in the VM program specifically exclude Part D costs, which puts physicians who administer Part B drugs in their office at a significant disadvantage compared to those who order/prescribe drugs covered under Part D, since the former would appear to have higher Medicare expenditures than the latter.
It may also disadvantage beneficiaries, as treatment options could become less available when providers are inappropriately held accountable for costs beyond their control. As a result, CSRO requested that CMS either remove Part B drug costs, or include Part D drug costs, as it evaluates resource use under the resource use performance category.
Regarding the rheumatoid arthritis and osteoporosis episode-based measures, we registered its opposition to the inclusion of these measures, which would only apply if a patient had two office visits in a 30-day time frame and did not include the cost of drugs. Neither measure has been adequately vetted by rheumatologists nor have they been used in any prior quality program. The use of these measures is premature because they have only recently been made public for comment and as such, they are unlikely to yield meaningful data or information because the vast majority of beneficiaries with a rheumatoid arthritis or osteoporosis diagnosis would not fall within the measures.
Clinical Practice Improvement Activities
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