“It may in fact be impossible for the Medicare program to transparently and reliably establish, collect, benchmark, assess and adjust payments based on quality measures for individual clinicians,” MedPAC said.
MedPAC's comment letter also suggested that the CMS' approach to this new system could lead to mass confusion because physicians are unlikely to understand why their Medicare payments are changing and what they need to do to improve their performance and increase their quality-based payments.
“A more promising avenue would be to encourage clinicians to organize into or join groups that take clinical and financial accountability for their patients, and have their performance assessed on the basis of a few key outcome measures,” MedPAC said.
Physicians also had mixed views on evaluating providers on an individual level for Medicare's Physician Compare website. The American Academy of Family Physicians warned that patients are overwhelmed by the volume of online information about quality measures that they don't understand, making it difficult for them to make informed decisions about where to seek care.
“We encourage the agency to avoid that outcome by including only the most important information about the physician as well as including educational products targeted at patients visiting the website,” AAFP said.
The AAFP also suggested that the CMS give group practices 90 days rather than 30 days to preview data about them before it's posted so they have enough time to review and validate the information and challenge the anything they think is wrong.
Insurers, meanwhile, warned that the CMS is creating a new opportunity for fraudsters by compensating physicians for the time they spend outside of face-to-face visits managing care for patients with two or more chronic conditions.
“Extra payment for (these) services presents an opportunity for fraud, waste and abuse,” America's Health Insurance Plans says. “We recommend that CMS develop an audit mechanism to determine if a physician's office has provided all of the service elements required for use of (this code.)”
As hospitals continue to buy up physician groups, the CMS is seeking to address concerns that Medicare is getting billed for a hospital facility fee for services that are delivered in the same outpatient setting as before the practice was acquired. For now, the agency proposed collecting data to learn more about the dynamic. The American Hospital Association, however, raised concerns about the way the agency intends to collect the information.
“Implementation details are missing and the methodology is untested,” the hospital association said. “Operational issues must be settled and adequately tested before full-scale implementation, and adequate time must be allotted for hospitals to adjust and operationalize their systems to accommodate this proposed change.”
The AHA also said the data collection would be very costly, time-consuming and burdensome, coming at the same time that providers are preparing for the mandatory October 2015 transition to ICD-10 procedure and diagnostic codes.
Follow Virgil Dickson on Twitter: @MHvdickson