AAFP Joins Effort to Decrease 2018 MIPS Reporting Period

In an April 16 letter to CMS Administrator Seema Verma, the organizations made a strong case for reducing the MIPS quality measure reporting period to a minimum of 90 consecutive days rather than a full calendar year.

"Despite being held accountable for data tracking and collection as of Jan. 1, 2018, physicians were not informed of basic eligibility information until early April to determine whether they must participate in the MIPS program," said the letter.

CMS further complicated the issue by changing the notification process, the organizations pointed out.

In 2017, CMS mailed letters to practices alerting them about their eligibility status; however, in 2018, physicians must go to the CMS website to check their status. To make matters worse, CMS did not even launch the MIPS eligibility tool there until the second week of April.

"Without direct outreach by CMS to physicians and group practices, many physicians will be left in the dark on their status," said the letter.

In addition, several policy changes occurred with the 2018 MIPS program that "complicate physicians' ability to determine their MIPS eligibility status," on their own, said the organizations.

For instance, regardless of CMS' good intentions when it expanded the 2018 low-volume threshold exemption to help small practices, the revision could change a physician's status regarding MIPS participation.

Also, the Bipartisan Budget Act of 2018 "modified MACRA (the Medicare Access and CHIP Reauthorization Act) to exclude Medicare Part B drug costs from MIPS payment adjustments and from the low-volume threshold determination of MIPS eligibility. As a result, physicians cannot rely on historic estimates from CMS and had to wait on notifications from CMS," said the letter.

The organizations said there was precedent for retroactively shortening a reporting period and reminded CMS that it did just that in 2015 and 2016 for the Electronic Health Record Meaningful Use Program and again for the 2017 MIPS program.

The letter also called on CMS to recognize that MIPS feedback reports -- which hold critical information for practices trying to make modifications and improvements -- will not be released until midway through 2018 at the earliest.

Implementation of a 90-day minimum reporting period would give physicians and group practices "greater flexibility to incorporate the first-year MIPS feedback into their 2018 performance and focus more of their attention on improving patient care, as opposed to just reporting."

Lastly, argued the organizations, instituting a 90-day reporting period would be consistent with CMS' efforts to reduce the burden on physicians and truly put patients over paperwork.

"The 2018 QPP final rule estimates the burden of recordkeeping and data submission will total 7.6 million hours with a cost of nearly $700 million," pointed out the letter. A shorter reporting period certainly would lighten that load.

For all of the above reasons, the organizations recommended CMS heed their request to adjust the quality reporting period to a minimum of 90 days.