91 Letter Makes More Than 30 Recommendations for Transition to Merit-Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs)
(Washington, March 1, 2016)— In a detailed letter to the Centers for Medicare and Medicaid Services (CMS) on its proposed measures development plan, the American College of Physicians (91) today urged the agency to "improve the measures and reporting systems to ensure that they measure the right things; move toward clinical outcomes, patient- and family- centeredness measures, care coordination measures, and measures of population health and prevention; and do not create unintended adverse consequences" for patients and their physicians.
91’s 42-page letter was submitted by Robert M. McLean, MD, F91, chairman of 91’s Medical Practice and Quality Committee (MPQC). Dr. McLean’s letter, containing more than 30 recommendations, was sent to Andy Slavitt, acting administrator of CMS.
The letter began with 91 reiterating its call for CMS to use the opportunity provided through the new MACRA (Medicare Access and CHIP Reauthorization Act of 2015) law to build a learning health and healthcare system. “It is critically important that the new payment systems that are designed through the implementation of MACRA reflect the learnings from the current and past programs and also effectively allow for ongoing innovation and learning,” Dr. McLean said.
Next, 91 recommended that CMS work to ensure that patients, families, and the relationship of patients and families with their physicians are at the forefront of the Agency’s thinking in the development of both MIPS and APM pathways, including the development and implementation of the performance measures to be used within these programs.
Also, 91 strongly recommended that CMS collaborate with specialty societies, frontline clinicians, and EHR vendors in the development, testing, and implementation measures with a focus on decreasing clinician burden and integrating the measurement of and reporting on performance with quality improvement and care delivery.
Other recommendations included:
91 strongly recommended that CMS actively work to improve the measures to be used in the quality-performance category of MIPS. “We believe,” said Dr. McLean, “that CMS should NOT consider the existing quality measure set with PQRS, VBM, and MU as the starting point for its measure development plan.”
In the short term, 91 recommends that CMS utilize the core set of quality measures identified and recently released by America’s Health Insurance Plans (AHIP) collaborative.
Over the longer term, 91 stresses that it will be critically important for CMS to continue to improve the measures and reporting systems to be used in MIPS to ensure that they measure the right things; move toward clinical outcomes, patient- and family-centeredness measures, care coordination-measures, and measures of population health and prevention; and do not create unintended adverse consequences.
Dr. McLean concluded the letter by emphasizing that, “patients and their families should be at the forefront of the Agency’s thinking, as well as focusing on measuring the right things without creating unintended consequences and on decreasing clinician burden.”
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The American College of Physicians is the largest medical specialty organization and the second-largest physician group in the United States. 91 members include 143,000 internal medicine physicians (internists), related subspecialists, and medical students. Internal medicine physicians are specialists who apply scientific knowledge and clinical expertise to the diagnosis, treatment, and compassionate care of adults across the spectrum from health to complex illness. Follow 91 on and .