DHPA today filed comments in response to CMS’s proposed rule implementing the Merit-Based Incentive Payment System (MIPS) and Incentives for Alternative Payment Models (APMs). This major proposed rule establishes new ground rules for physician payments under the MACRA legislation passed by Congress last year.
MACRA represents a fundamental change in the way physicians are paid under Medicare in two ways. First, payments to physician groups will increase or decrease based on their performance under certain quality, resource use, and other reporting programs. Second, physicians who participate in APMs like ACOs, bundled payment arrangements, and other new models of care will receive a Medicare payment bonus and certain other incentives.
Our comments remind CMS of the fundamental importance of independent gastroenterology practice and make a number of actionable suggestions to ensure that the physician payment system works for GI physicians working in the independent setting. In its comments, DHPA:
- Asks CMS to provide flexibility under the Stark Law so that independent gastroenterology practices can properly reward efficient and high-quality physicians, and participate in a wide range of models to coordinate care across sites of service.
- Requests a wider range of options to report on measures related to care coordination and clinical practice improvements under the MIPS.
- Advocates that CMS change the “episode of care” rules it proposes to use to evaluate specialty services, so that such “episodes” can be triggered in the ASC setting for services like colonoscopies and other endoscopic procedures.
Click here to read the full comment letter.