Physician groups are pressuring the Centers for Medicare and Medicaid Services to forestall looming penalties associated with the Merit-based Incentive Payment System, citing systemic challenges facing doctors and the ongoing effects of the COVID-19 pandemic.
MIPS, as the Medicare reimbursement program for physician services is known, makes doctors eligible for bonus payments or penalties based on factors such as quality, cost and electronic health record use. Medical societies have expressed concern about the payment system since Congress created it in 2015, and the Medicare Payment Advisory Commission has recommended that lawmakers replace it with a new method of setting reimbursements.
Related: Proposed cuts to Medicare physician payments spark calls for overhaul
CMS exempted doctors from collecting and reporting MIPS data during the early stages of the pandemic but reimposed those requirements last year and required medical offices to submit such information this March.
Next year, physicians that didn't meet the program's benchmarks in 2022 will be assessed penalties for the first time since MIPS debuted in 2017. The American Medical Association estimates that doctors could see payment penalties of up to 9%, on top of a 1.25% reduction in Medicare reimbursements that CMS proposed in July.
CMS is expected to publish the physician fee schedule final rule within weeks as the AMA and allied organizations ramp up their campaign to stop the cuts and to accommodate doctors at risk of MIPS penalties.
"When you adjust for inflation, the payment rate to physicians who care for Medicare patients has dropped 26% since 2001," AMA President Dr. Jesse Ehrenfeld said at a news conference in Washington Wednesday. "I don't know many businesses in any industry that could withstand a 26% drop in revenue and still survive," said Ehrenfeld, an anesthesiologist who practices in Milwaukee and is a professor at the Medical College of Wisconsin.
Small and independent medical offices, especially in rural and other underserved areas, are most vulnerable, Ehrenfeld said in a statement Thursday. "With their tight operating margins, these practices simply cannot sustain a combined double-digit payment cut on top of the rising costs of practice," he said.
Doctors who treat Medicare beneficiaries will almost certainly be subject to MIPS penalties if the regulation takes effect as proposed, said Dr. Stephen Epstein, a Boston-based practitioner who spoke on behalf of the American College of Emergency Physicians.
Moreover, many physicians were caught off guard when CMS reinstated the data collection and reporting requirements last year, Epstein said.
Physician groups are urging CMS to reconsider, Epstein said. "You've made the bar so high that we're anticipating the practices that are still reeling are now going to get another hit, and you know that most practices are going to be losing money as a result of this program. Maybe we should lower the threshold, at least this year," Epstein said.
The AMA wrote CMS last month, pleading for lenience. Doctors need more time to request targeted reviews to recalculate their MIPS scores and to seek reporting exemptions because of COVID-19, the AMA wrote. The agency also should reweigh the MIPS cost factor, the association urged.
MIPS imposes an "extreme administrative burden" on physicians with "no discernible benefits," Ehrenfeld said in his statement.
Furthermore, physicians don't understand how the penalty process will work and need answers, said Brian Outland, director of regulatory affairs for the American College of Physicians.
"We want to be sure that the scoring of our physicians is accurate, and that there are no problems with the scoring, Outland said. Doctors and medical societies also need more information about how severe the penalties may be and what they can do to mitigate them, he said.
