Providers are pushing back against proposed codes required by MACRA to identify which clinicians provide services. The codes are an integral part of the payment reform, as they are an effort to compare resources across practices.
Industry leaders say the proposed version of the patient relationship codes, which were mandated by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015, would be a burden and wouldn't accomplish the goal of effectively measuring resource use, a major performance category under the Merit-based Incentive Payment System (MIPS).
The claims codes, which would be required if physicians choose to participate in a MIPS, would determine each provider's level of responsibility and the costs associated with providing care.
In April, the CMS proposed tracking three (PDF) patient relationship areas: continuing care, acute care, and acute care or continuing care. The proposed codes identify what care is provided by a primary care physicians, which clinician was providing continuing specialized chronic care to the patient, and who is overseeing the coordinated care process of a patient during an acute episode.
Comments on how to crack the codes were due August 15. Instead of collecting responses via a Federal Register docket, the agency set up an email address for stakeholders to send feedback.
As presented, the proposed codes “will simply lead to more 'administrivia' for physicians, will not achieve the intended aim of facilitating resource use allocation among physicians and will not lead to better outcomes of care," Dr. Robert Wergin, chair of American Academy of Family Physicians' board, said in a letter.
The group felt the codes were too vague and could lead to confusion. For instance, the continuing care relationship area has one category describing a clinician who is the primary care provider and a second describing a clinician who provides specialized care. As written, a family physician could fit into either category.
"Patient relationship categories must be mutually exclusive in a given situation, so a physician does not have to choose among two or more equally applicable categories for a patient in a particular circumstance," Wergin says. "When applying patient relationship codes to encounters, there could be confusion if the clinician has different relationships based on the patient's different diagnoses."
Specialists were also concerned that the codes in their current form will be confusing to say, oncologists who often engage a multidisciplinary approach to cancer care, said Laura Thevenot, CEO of the American Society for Radiation Oncology.
Both organizations called for tweaks and said the CMS must test any codes before implementing them nationally.
“A phased-in approach will provide adequate time for gathering data on the patient relationship categories and codes, as well as the episodes of care data that will also be collected,” Thevenot, says.
The law requires providers to begin to include the patient relationship codes on their claims starting Jan. 1, 2018. The CMS is expected to unveil a modified proposed set of codes by the end of November of this year.
