Hospital and physician groups are cautioning the CMS that it needs better measures before it ties physician pay to quality and outcomes.
The warnings came in letters from the American Hospital Association, American Medical Association and other provider groups in response to the CMS' request for comments on how it should structure the new physician payment policy that was included in the Medicare Access and CHIP Reauthorization Act passed earlier this year. The comment period ends Tuesday.
The law eliminated the rarely implemented sustainable growth-rate formula in favor of a value-based payment system to reward or limit payments to doctors under traditional fee-for-service medicine. The new merit-based incentive payment system is slated to go into effect in 2019.
The American Medical Association has outlined 10 principles it would like the CMS to consider while making the payment transition, including making requirements flexible enough for a variety of patient populations and organizational structures.
The AMA also said current programs for gathering data and measuring Medicare quality cannot simply be combined to form the basis for the new merit-based system.
“These currently separate programs must be carefully assessed, revised, aligned and streamlined into a coherent and flexible system that is truly relevant to high-value care,” they wrote.
The American Medical Informatics Association said it supports payment based on outcomes but is concerned that electronically specified clinical quality measures are not accurate and complete enough.
“As we transition away from fee-for-service payment, so too must we move away from the quality measurement paradigm underlying that system,” the comment reads. “Despite earnest efforts, quality measurement has not become 'a byproduct of care delivered,' as envisioned, and we are concerned the current mode is insufficient to enable this.”
Multiple physicians groups and medical organizations have previously requested the federal government delay implementation of electronic health-record requirements that are to be used to help determine physician quality under MACRA.
The CMS will take the comments into consideration before it issues a proposed rule, which is expected sometime in the spring of next year.