We took time to respond to the October 1st Federal Register. For those of you familiar with Centers for Medicare and Medicaid Services (CMS) current incentive model, you know it is called Physician Quality Reporting System (PQRS).
We responded to CMS Request for Information to their questions on a Merit-Based Incentive Payment System (MIPS).
We pointed out that nonphysician eligible professionals won't be included in MIPS until 2021. This means that none of you who are providing quality care will have an opportunity to receive incentive payments for at least 2 years after the implementation of MIPS.
For MIPS it should be a requirement that all measures be endorsed by the National Quality Forum (NQF). Measures should be required to have psychometric properties at an acceptable level of validity, reliability and responsiveness.
Claims-based reporting needs to be eliminated. If the true goal is to improve quality of care, nonphysician providers need timely feedback. Electronic reporting through an electronic health record (EHR) or registry that interfaces with an EHR is recommended. The current PQRS is overly complicated with complex domain requirements and cross cutting measures category. For rehabilitation providers, a simple solution is functional status measures.
Resource use measures relevant to rehabilitation professionals do not currently exist in the value-based modifier program. We recommend risk adjusted values to be used to determine if efficiency and effectiveness attributes are met for an episode of care.
We advise that CMS establish a standard of performance for rehabilitation professionals. The standard could be defined by effectiveness (outcome/efficiency) which would be reported annually on an aggregated basis. The current process measures do not equate to effective and efficient care nor any effect of the care provided to the beneficiary. We also recommend that rehabilitation providers report the percentage of treated beneficiaries with a complete set of data.
We support the use of functional measures that are not burdensome for beneficiaries. We recommend NQF endorsed measures, computerized adaptive testing, and a system that risk adjusts data for predictive analytics to determine expected outcomes.
Of course our comments were far more eloquent than this summary. If you are interested, you can read our full letter to CMS.