On September 8, 2015, the Medicare Payment Advisory Commission (MedPAC) released its comments to the proposed rule that will begin implementing the new Merit-Based Incentive Payment System (MIPS) for physician services, in which it cautions CMS not to over-complicate the quality measurement system.  Under MIPS, payments to physicians and other healthcare professionals will be adjusted based on performance measures beginning in calendar year 2019.  These performance measures would be based on quality, resource use, clinical practice improvement activities, and meaningful use of certified electronic health record technology, resulting in a composite score.  The composite score would then be measured against a performance threshold and the physician’s payments would be adjusted accordingly.  

While MedPAC supports physician performance measures, its comments caution CMS to avoid increasing the complexity of Medicare’s quality measurement systems.  Because of the resources required to monitor and evaluate individual physicians and then redistribute payments, MedPAC recommended a more streamlined approach to developing quality measurements.  MedPAC noted that for physicians organized in groups that assume clinical and financial accountability for their patients, performance assessments could be successfully based on outcome measures such as potentially avoidable hospital admissions, emergency department visits, and readmissions.  For physicians who are not responsible for a group of beneficiaries, the most that can realistically be achieved through any performance measurement framework like MIPS within the Medicare fee-for-service space, MedPAC argues, may only be able to identify “extreme and persistent outliers” among quality performance measures.  Thus, only the outliers would have their payments adjusted.  For this reason, MedPAC advocates for a “streamlined approach to the quality measurement system” that will permit a “more rational use of resources and effort for both CMS and providers.”

In addition to commenting on MIPS and quality measurement, MedPAC also submitted comments regarding, among other items, the proposed rule’s “alternative payment models,” physician self-referral updates, valuation of specific codes, and advance care planning services.  A detailed summary of the proposed rule is available in our prior Health Headlines article here.  The comment period expired on September 8, 2015, and publication of the final rule is expected by November 1, 2015.