Doctors need more support, not penalties, from CMS

August 10, 2020

Proposed changes to the QPP need to better accommodate physicians dealing with COVID-19, says ACP.

CMS released its proposed changes to the Quality Payment Program for 2021, but the American College of Physicians says that they don’t do enough to help doctors dealing with the effects of the COVID-19 pandemic on their practices.

“Physician practices are reeling this year thanks to the COVID-19 pandemic, and they are having to make major shifts in how they conduct business” said Jacqueline W. Fincher, MD, MACP, president, ACP, in a statement. “With the financial ramifications of the decrease of in-person office visits, the shift to telehealth, and the major practice design changes that must be made to deal with the novel coronavirus, the resources a practice has to handle other practice transformation activities are severely compromised.”

The proposed QPP rule for 2021 includes some accommodations to help practices. CMS proposes to reduce the Merit-based Incentive Payment System performance threshold from 60 to 50 points, and would use performance year data to score quality measures instead of relying on historic benchmarks. The changes proposed for 2021 reporting criteria were minimal and CMS offered no broad scale exclusions or protections for the 2021 performance year in the proposed rule.

CMS also proposes to delay the start of the new MIPS Value Pathway until at least 2022. ACP supports the MVP concept as an opportunity to reduce burden. CMS attributed the delay in the start date to the challenging circumstances presented by COVID-19 and emphasized the importance of a gradual implementation, which aligns with previous ACP recommendations.

Substantial changes were proposed to quality reporting for Accountable Care Organizations and other Alternative Payment Models, including retiring web interface reporting. The changes are intended to reduce reporting burden, but ACP has concerns that the reduced measure set eliminates reporting flexibility and that the timeline for ACOs to implement these sweeping changes is too short. CMS offered no additional protections for APM participants from financial risk requirements or performance-based payment adjustments. The proposed rule also did not address the scheduled increase in the Qualified APM Participant thresholds next year, which is expected to result in far fewer clinicians qualifying for the Advanced APM bonus. ACP has previously requested that APMs be broadly exempted from risk-based payments and receive protection against performance-based penalties and has encouraged the Department of Health and Human Services to exercise its authority to adjust the patient count QP threshold.

“ACP has long supported the move toward value-based payments, and we continue to do so. But right now, our practices are in crisis,” Fincher said. “The effects of the COVID-19 pandemic on our health care system will carry through for quite some time. Right now, practices need support—not penalties—as they continue to recover and rebuild. We hope that CMS hears our concerns and that we can work with them to include more effective accommodations for physician practices in the final rule.”