MarsdenAdvisors asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting programs in comments submitted on both the 2022 Quality Payment Program (QPP) proposed rule and the 2022 ASC Quality Reporting Program (ASCQR) proposed rules.

See our previous blogs for a summary of the proposed changes to the QPP and the ASCQR.

Quality Payment Program Comments

In our comments on the 2022 QPP Proposed Rule, we focused on problems that our clients currently face under MIPS and anticipated problems with proposed changes. Broadly speaking, we voiced concerns that CMS is making meaningful compliance with MIPS increasingly difficult.

Specifically, CMS is crippling the value of MIPS through the following:

• Removing significant numbers of specialty-specific Quality measures,
• Proposing to remove points for being EHR integrated with a specialty QCDR (such as DataDerm or the IRIS Registry), and
• Lumping together all mid-level providers, even those who work at specialty-only practices, as primary care providers.

These existing and proposed issues have made it increasingly difficult for our specialty practices to be evaluated only on the care they provide within their scope-of-practice in both the Cost and Quality categories. In addition, we oppose removing credit for specialty-specific QCDR use which has driven not only quality improvement, but also clinical advancement through research.

We also voiced concerns about how MIPS scoring is currently being conducted. For example, when more than one Promoting Interoperability (PI) category score is submitted for the same group or clinician, CMS assigns a category score of 0. This breaks from current policy, finalized in the 2018 QPP Final Rule, which states that categories with multiple scores for the same clinician or group will receive the highest of the available scores. We have seen this issue impact several practices which, unknown to them, had data submitted on their behalf by vendors.

Finally, we asked CMS not to discontinue the MIPS track when the MIPS Value Pathways (MVPs) track is more established in 2028. Doing so would require all clinicians to participate in MVPs. While MVPs are intended to be either specialty- or condition-specific, six years is an insufficient amount of time to develop a truly representative catalog of MVPs. This rapid implementation timeline would have the result of prescribing inappropriate measures to many specialty clinicians and, likely, would result in low Quality scores from measures that do not represent their practice or care.

ASCQR Comments

CMS is proposing to require reporting on two highly burdensome survey measures – ASC-11: Cataracts – Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery and ASC-15a-e: OAS CAHPS Survey. These measures create considerable burden on ASCs and there are significant concerns over the inappropriate nature of the cataract surveys being attributed to the ASC facility rather than to the individual surgeon. In our comments on the 2022 ASCQR Proposed Rule, we asked CMS to ensure that these measures remain voluntary in all future years.

Next Steps

• Watch our webinar on the 2022 MIPS proposed changes.
• Review our Top 2022 Proposed MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.

If you want hands-on, personalized assistance on MIPS or the ASCQR, contact us and we will have your back.