PAI Submits Comments in Response to CY 2019 QPP Proposed Rule and Includes Findings From In-Field Engagement with Physicians and Practices
On September 10, PAI submitted comments in response to the CY 2019 Medicare Physician Fee Schedule and Quality Payment Program (QPP) Proposed Rule. In its comments, PAI urged CMS to:
- Implement burden reductions for E/M documentation guidelines and requirements but urge the Agency against tying them to any reduction in payments for E/M services.
- Avoid making drastic changes to MIPS submission mechanisms and its categories (including scoring and reporting requirements/options) that would require substantial retraining for physicians and other eligible clinicians.
- Maintain the weight on the cost category at 10 percent and refrain from applying the new episode-based measures until further development and testing is conducted.
- Continue to engage with stakeholders and work closely on the development of cost category measures that more accurately assess the utilization of health care services and appropriately attribute costs.
- Refrain from reporting QPP data on Physician Compare until there is more predictability, continuity, consistency, and decreased complexity in the program.
Additionally, over the past year, PAI has been engaging with physicians and practices in-the-field in both one-on-one and group discussions. These discussions have helped identify current challenges and opportunities for improvement for both the QPP as well as other value-based programs. Through these discussions, PAI was able to identify the resources, modifications to the current program, and/or assistance that might be most useful to physicians and practices to address existing barriers and gaps. A complete summary of findings was included as an Addendum to the comment letter.
See PAI’s complete comments here and the Addendum here.