May 3, 2024: Medicare Payment Reform Advocacy Update

In collaboration with the national medical specialty societies, the AMA proposed (PDF) to the Centers for Medicare & Medicaid Services (CMS) an alternative framework for Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) to address shortcomings with current and proposed MVPs.

The alternative framework categorizes quality and cost measures into condition-specific subdivisions within a broader MVP. Physicians who specialize in treating a particular condition would be able to clearly identify the available measures for that condition and register to be held accountable for those condition-specific quality and cost measures within the MVP.

By creating MVPs through the proposed framework, CMS and physicians could also more easily identify and remedy gaps in measurement and scoring challenges, such as no or limited condition-specific measures or measures without a benchmark. This framework would address many of the problems with the current MVPs for many specialists, is feasible for CMS to implement, and helps inform patient decision making. The AMA shared two examples developed by cardiologists and ophthalmologists. Finally, the AMA encouraged CMS to obtain feedback on the framework in the forthcoming 2025 proposed rule.

In a letter (PDF) to CMS, the AMA reiterated its recommendation that CMS remove the Total Per Capita Cost (TPCC) cost measure from MIPS or, at a minimum, remove it from any MVP in which there is an episode-based cost measure. If the TPCC continues to be used, it must be revised so that it is either limited to or focused on the aspects of cost that physicians can reasonably control, and so that it avoids creating any incentive for physicians to undertreat patients. Furthermore, the letter expressed support for addressing the problem of attribution to a group practice that exclusively provides specialty care based on billing by nurse practitioners, physician assistants and clinical nurse specialists within the group practice.

The AMA has previously written to CMS expressing concerns that TPCC was inappropriately attributed to radiologists (PDF) and hospitalists (PDF) due to this problem. The AMA urges CMS to modify the attribution rules to include a mechanism for using patient relationship codes and to seek input from physician specialty societies about how to make this new attribution method work effectively. Finally, the AMA again urged CMS to provide physicians with quarterly feedback reports during the performance period about their cost measures.

As Congress has failed to entirely stop Medicare physician payment cuts over the past two years, physician practices are left with less financial stability during a tenuous time—already rocked by the challenges of COVID-19, physician workforce shortages and the Change Healthcare cybersecurity attack. It is clear the Medicare payment system is unsustainable, and holistic reform is needed to protect patient access to care.

Register now for this Advocacy Insights webinar—June 4 at Noon, Central—to hear about the latest AMA efforts on Medicare physician payment reform: what’s happening on Capitol Hill, how the AMA’s grassroots campaign is raising the volume, and what to expect on the regulatory side—particularly as the proposed rule for the 2025 Medicare physician fee schedule is expected later this summer.

Moderator:

• Jesse M. Ehrenfeld, MD, MPH, president, American Medical Association

Speakers:

• Margaret Garikes, vice president, Federal Affairs, AMA
• Rob Jordan, vice president, Political Affairs, AMA
• Jason Marino, director, Congressional Affairs, AMA

• May 3, 2024: Advocacy Update spotlight on Change Healthcare cyberattack adverse impact
• May 3, 2024: National Advocacy Update
• May 3, 2024: State Advocacy Update