On January 2, 2018, the American Society of Anesthesiologists® (ASA) submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) focused on ensuring physician anesthesiologists have ample opportunities to meaningfully participate and succeed in either the Merit-based Incentive Payments System (MIPS) or Advanced Alternative Payment Models (APMs) pathways under the Quality Payment Program (QPP). ASA’s 14 page submission was in response to the 2018 QPP Final Rule of the Medicare Access and CHIP Reauthorization Act (MACRA).
ASA urged CMS to:
- Approve and post QCDR measure specifications by December 1 prior to the reporting year, similar to the process used for MIPS measures. ASA noted that physician anesthesiologists and their practices need sufficient time to update their processes and be prepared to collect appropriate quality measure data. In the case of completely new measures, clinicians need to understand the targets they are trying to meet and will need time to familiarize themselves with the measures and their associated benchmarks. Given that CMS is moving to a 12-month reporting period, the timely posting of measures becomes even more critical.
- Use performance year 2018 to hone the facility-based measures program both from an internal and external perspective. CMS must better detail how hospital quality scores will be translated into MIPS Quality and Cost scores and how will eligible clinicians and their practices be informed that they have met the threshold for choosing the facility-based reporting option.
- Reconsider its approach to approving APMs to include non-primary care physicians and broader patient populations. ASA strongly recommended the agency ensure sufficient support for the independent development of pediatric and maternity models. Likewise, future APMs should take into serious consideration perioperative care for Medicare patients, especially those patients who receive care within a perioperative surgical home (PSH).
ASA also commented on the quality measure reporting threshold, seeking to lower data completeness to 50 percent of applicable cases. ASA expressed appreciation to the agency for finalizing its proposal to implement the PSH Care Coordination Improvement Activity for the 2018 performance year and in the future.