Quality Measures Must Reduce Administrative Burden, AAFP Tells CMS

In responding to the agency’s advance notice of 2024 payment rates for Medicare Advantage and Part D plans, the AAFP focused on how elements of the Inflation Reduction Act that go into effect next year will reduce beneficiaries’ out-of-pocket costs. The Academy also reacted to CMS’ planned move to align quality measures across its programs while changing the risk-adjustment model that modifies Medicare Advantage capitated payments based on beneficiary characteristics and clinical diagnoses.

Quality Measurement and Risk Adjustment

The letter marked the Academy’s initial response to what CMS calls the “Universal Foundation.” That initiative, which the agency says is meant to standardize and better align quality performance measures across its health care programs, has drawn mixed reactions from family physicians.

“The intention of the Universal Foundation is a step in the right direction toward reducing the burdens associated with the complex maze of measures and measurement processes that currently exist,” the AAFP wrote, “but further work must be done to achieve meaningful, long-term improvement in the evolution of measurement.”

The letter urged CMS to avoid adding administrative complexity to physicians’ quality measurement by collaborating with private payers before launching Universal Foundation. The agency also should “work across health care stakeholders to promote a core measure set for primary care that focuses less on existing process measures and more on outcome measures, patient-reported measures and more progressive measures that truly reflect the value of primary care,” the Academy said.

“We urge CMS to use its authority to better align the incentives and accountability in the MA program to ensure that physicians and practices receive investment and support from MA organizations to improve care, as well as financial benefits for successful performance,” the AAFP said.

The Academy also expressed reservations about several technical updates to Medicare Advantage’s “hierarchical condition categories” risk-adjustment model. Again, the letter praised the agency’s intent but called for greater deliberation.

The Academy said it would support a delayed or extended implementation of model changes, rather than full implementation in 2024, “to prevent unintended consequences falling on patients and physicians.”

“We further recommend CMS consider additional guardrails to prevent MA organizations from passing potential revenue reductions onto the physician practices they contract with and ensure MA organizations are using Medicare payments to invest in and support the provision of high-quality primary care,” the letter added.

Vaccine Access

While lauding CMS’ swift implementation of the Inflation Reduction Act’s mandated end to cost-sharing for adult vaccines recommended by the Advisory Committee on Immunization Practices, the Academy called for further action that would let patients get all of the recommended vaccines from their usual primary care source.

“Physicians continue to provide important vaccine counseling for patients but are then forced to send their patient to a pharmacy to receive their vaccine, as physicians cannot bill for Part D-covered vaccines,” the letter said. “This hand-off often results in patients forgoing important vaccines when transportation, timing or trust impede access to pharmacy-administered vaccines.”

Value-based Care

The Academy took advantage of CMS’ annual advance notice to call for the accelerated adoption of primary care alternative payment models in Medicare Advantage and across all payers.

“We urge CMS to continue promoting the adoption of value-based prospective primary care payment models in MA as one key strategy to insulate and strengthen primary care as the agency makes important changes to protect the MA program,” the AAFP said.