Opposition to Value-Based MIPS Replacement
Following discussions at several recent meetings that have drawn the opposition of ASCRS and the Alliance of Specialty Medicine, the Medicare Payment Advisory Commission (MedPAC) voted 14 to 2 this week to recommend repealing MIPS and encourage physicians to move from Medicare fee-for-service into Advanced APMs. Physicians remaining in fee-for-service would be forced to participate in a proposed “Voluntary Value Program” (VVP), which would require physicians to identify other physicians to join with in large virtual groups to be measured with population-health claims-based measures. During the discussions leading up to the vote, several commissioners noted their concerns that MIPS would not improve quality or value of care, but were not convinced that MedPAC’s alternative would either. They noted that additional work would need to be undertaken to develop the alternative if Congress acted on their recommendations. Throughout MedPAC’s discussions on the topic, ASCRS has joined with the Alliance of Specialty Medicine to oppose this proposal, including sending another letter this week reiterating our opposition. We reminded MedPAC that there are no specialty-specific Advanced APMs, and the population-based measures MedPAC proposes to use are not relevant to specialists. During the discussion, commissioners noted they had not received any feedback from the medical community or other stakeholders in support of their recommendation.
While we are concerned with MedPAC’s recommendation, it is important to recognize that MedPAC is an advisory body with no force of law. Implementing this proposal would require Congress to act and make major changes to the MACRA statute. Congress rarely follows MedPAC’s advice and is not likely to make changes to MACRA, which had broad bipartisan support when it was passed in 2015.
Opposition to Primary Care Proposal
In addition to voting on the VVP recommendation at this week’s meeting, MedPAC also continued discussing a potential proposal to re-balance the physician fee schedule to provide additional payment to primary care physicians and specialists who provide primary care services, at the expense of surgical specialties. ASCRS joined with the surgical coalition in a separate letter to MedPAC expressing concern with proposals to rebalance the fee schedule, as the AMA’s Relative Value Update Committee (RUC) has already undertaken efforts to revalue certain misvalued codes, which has resulted in the reduction of many surgical and procedural codes and increased the value of E/M services. In addition, CMS is now reimbursing new CPT codes for chronic care and mental health management, which increase reimbursement to primary care specialties. Finally, the letter reminds MedPAC that while there are documented physician shortages in primary care, this rebalancing is unlikely to increase recruitment and may exacerbate existing shortages in several specialties. We urged MedPAC to leave code valuation and fee schedule relativity as a function of the RUC. During the meeting, commissioners did not reference our letter directly, but also expressed doubt that the proposal would increase recruitment of primary care physicians. MedPAC will continue discussing this topic in coming months, and will develop recommendations later in the year. We will keep you updated.