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QPP Proposed Rule Section
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AAPM&R Recommendations
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Low Volume Threshold
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AAPM&R supports the expansion of the low-volume threshold, and urges CMS to notify individuals and groups as soon as possible that they qualify for the low-volume threshold exemption.
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Definition of a MIPS Eligible Clinician
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AAPM&R opposes including items or services beyond the physician fee schedule, especially Part B drugs, when determining MIPS eligibility, applying the MIPS payment adjustment, and in cost score calculations.
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Small Practices
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AAPM&R recommends CMS consider the option to expand the proposed small practice size determination period to 24 months with two 12-month segments of data analysis when determining small practice size.
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Virtual Groups Election Process
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AAPM&R urges CMS to expand the virtual group election process beyond December 1, 2017 to December 31, 2017 during its first year of implementation and provide special scoring accommodations for virtual groups for the first year.
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MIPS Performance Period
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AAPM&R urges CMS to reduce the quality performance period to a minimum 90-day period within the CY 2018 and up to and including the full CY 2018.
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Performance Category Measures and Reporting
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AAPM&R encourages CMS to reconsider multiple data submissions for all categories, especially the quality category, to only one data submission mechanism.
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Selection of MIPS Quality Measures for Individual MIPS Eligible Clinicians and Groups Under the Annual List of Quality Measures Available for MIPS Assessment
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AAPM&R supports the proposed substantive changes to the Closing the Referral Loop: Receipt of Specialist Report measure.
AAPM&R continues to urge CMS to add codes such as 99201-5 and 99211-5 to the Functional Assessment measure to be reportable by physical medicine physicians. If CMS cannot do this in time for the 2018 performance period, AAPM&R recommends CMS should remove this measure from the Physical Medicine Specialty Measure Set since it is currently not reportable by members of our specialty.
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Cost Performance Category
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AAPM&R supports:
-weighting the cost category at 0% for the 2018 reporting year
-the removal of general cost measures
-the removal of the ten episode-based cost measures adopted for 2017 reporting
- development of new episode-based cost measures
- use of cost measures which are adjusted for social risk factors
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Improvement Activity Criteria
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AAPM&R supports the inclusion of language in the 2018 QPP proposed rule to explicitly recognize Continuing Medical Education (CME) as an Improvement Activity within the Merit-Based Incentive Payment System (MIPS). As a member of the Council of Medical Specialty Societies (CMSS), we refer CMS to their letter of support for this specific Improvement Activity.
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Advancing Care Information (ACI) Performance Category
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AAPM&R urges CMS to offer clinicians the broadest selection of measures to choose from for purposes of both the base and performance Advancing Care Information score and to not require the use of any single measure to receive a score in this category.
AAPM&R urges CMS to recognize the value that clinical data registries bring to health care and promote their use by establishing an alternative pathway that recognizes physicians utilizing an EHR to participate in a clinical data registry as satisfactorily achieving full credit for the Advancing Care Information category.
AAPM&R strongly believes that clinicians who do not have access to an immunization registry should, at the very least, be able to earn the full 10 percentage points for reporting to another registry, such as a specialized or clinical data registry.
Reweighting of the ACI Category: AAPM&R urges CMS to automatically reweight the ACI performance category for clinicians who predominantly practice in settings such as Comprehensive Inpatient Rehabilitation Facility (IRF; POS 61) and Skilled Nursing Facility (SNF: POS 31).
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MIPS Final Score Methodology
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AAPM&R supports the availability of facility-based measurement to consider clinician performance for the cost and quality performance categories, as a voluntary option.
AAPM&R asks CMS to consider further developing this policy in upcoming years to include measures adopted under the inpatient rehabilitation facilities (IRF) and skilled nursing facilities (SNF) quality reporting programs.
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Calculating the Final Score
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Complex Patient Bonus: AAPM&R encourages CMS to increase the complex patient bonus to the same amount (5 points) or a higher bonus than proposed for small practices.
Small Practice Bonus: AAPM&R supports the proposal to add the small practice bonus of 5 points to the final score of those clinicians and groups who meet the small practice criteria.
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MIPS Payment Adjustments
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Establishing the Performance Threshold: AAPM&R supports maintaining a low performance threshold of 3 for performance year 2018
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Third Party Data Submission
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AAPM&R supports and refers CMS to the comments of the Physician Clinical Registry Coalition related to QCDRs of which AAPM&R is an active member.
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Public Reporting on Physician Compare
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AAPM&R urges CMS to extend the current preview 30-day period to 90 days.
AAPM&R recommends that CMS indicate whether a physician satisfied the reporting requirements for each of the performance categories with a green check mark, as it has done previously for the EHR Incentive Program.
AAPM&R urges CMS to not publicly report based upon social risk factors on Physician Compare until research on risk adjustment has been vigorously tested and validated.
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Overview of the APM Incentive
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AAPM&R requests that CMS provide more clarity on how it will calculate the revenue of participants in an APM entity and a clearer description of its plan to average revenues to arrive at a determination of whether the APM meets the financial risk criterion.
AAPM&R recommends that CMS remove the requirement that a medical home must be limited to the list of specialties provided
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Other Payer Advanced APM Criteria
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AAPM&R recommends aligning Other Payer Advanced APM risk requirements with that of Medicare Advanced APMs
AAPM&R recommends that CMS increase the availability of the Payer-Initiated Process and strengthen requirements for payer submission of data
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