As part of its campaign to fix the unsustainable Medicare physician payment system, the AMA is outlining in a quick, easily navigable fashion the policy changes needed to remove obstacles to the successful use of clinical data registries in the program.
The AMA’s two-page explainer on clinical data registries in the transition to value-based care (PDF) outlines how the process of approving clinical data registries under the Merit-based Incentive Payment System (MIPS) is “complex and cumbersome,” and details how “the lack of accessible cost data inhibits progress toward true value-based care.”
This flawed approach means that “physicians’ ability to leverage their participation in these quality improvement efforts for MIPS and engage in continuous learning has been limited.”
The AMA is leading the charge to reform the Medicare payment system, which is the AMA’s top advocacy priority.
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How do registries help improve care?
Clinical data registries provide timely feedback to participating clinicians on patient outcomes and the quality of care they provide to patients. The dynamic feedback that registries provide enables physicians to identify weaknesses and implement changes—often in real time—that create high-value care and track improvements over time.
But physicians who practice in larger institutions often have little control over decisions about quality-measure selection or about participation in a clinical data registry, which is known as a “qualified clinical data registry within MIPS. Because of that, many of these registries and their measures are underused.
CMS has also made it very difficult for specialty-led registries to continue participating in the MIPS program. Annually, CMS has changed the quality requirements, measure specifications or technology functionality, which has provided the perception among specialty-led measure developers and QCDRs that the changes are arbitrary and lack evidence or reason. The annual changes are also administratively burdensome and do not allow sufficient time for implementation. Therefore, there must be consistency from year to year, especially if CMS would like to move to measuring improvement.
In addition, the Centers for Medicare & Medicaid Services (CMS) takes a flawed approach to measuring the health IT-focused “Promoting Interoperability” component in MIPS that prohibits physicians’ use of innovative information technology, such as qualified clinical data registries that can move medicine forward.
“Well-designed clinical data registries, with access to claims data, incorporate all the elements of value-based care under MIPS: quality, cost, health information technology, and improvement activities,” the AMA explains, noting that CMS has failed “to recognize their overarching benefits.”
AMA outlines a new approach
The AMA has long been concerned about the undue administrative burden placed on physicians subjected to MIPS reporting requirements, the program’s lack of improvement in patient outcomes and quality of care, and the limited scope of quality measures for specialists.
With substantial input from national medical specialty societies and physicians across the country, the AMA has developed a statutory proposal to replace the MIPS tournament model of payment adjustments with a more sustainable approach tied to annual payment updates, give the Centers for Medicare & Medicaid Services incentives to share data with physicians, and improve the measures.
The MIPS replacement, called the “Data-Driven Performance Payment System,” would freeze the performance threshold to avoid a penalty at 60 points for at least three years and call for a study to improve the threshold methodology. It would also eliminate the win-lose style payment adjustments that include a maximum penalty of negative 9% and instead link performance in MIPS to a percentage increase or decrease of the annual update, which would better align across Medicare payment programs, such as the Hospital Inpatient Quality Reporting System. More details about this proposed replacement for MIPS will be formally announced in the coming weeks.
This replacement system would replace steep penalties that are unevenly distributed, ensure timely access to data, reduce unnecessary administrative burden, and increase the clinical relevance of the program to physicians and their patients.
Without making fixes like these to the Medicare payment system, physicians fear they will no longer be able to care for Medicare patients because it isn’t feasible from a business perspective. Compliance with the MIPS requirements in 2019 cost $12,800 per physician per year, which is likely an underestimate of the costs of participate today as CMS continues to increase the reporting requirements.
“Physicians who take care of Medicare patients are finding it difficult to take care of them because sometimes it costs more to see and take care of the patients then they're actually reimbursed for the visit, so this is problematic in our area. Many physicians are limiting the number of Medicare patients they'll see because they lose money if they don't. Some clinicians are actually refusing to see Medicare patients at all,” said Dale Blasier, MD, a pediatric orthopaedic surgeon in Little Rock, Arkansas.
Dr. Blasier also noted that Medicaid payments physicians receive are closely tied to what the Medicare pay rate is. Dr. Blasier is among the practicing physicians and AMA members who have taken time to share their firsthand perspectives on the impact of unsustainable Medicare physician payment in interviews with the AMA.
Catch up on the Medicare basics
While the AMA is working relentlessly to build understanding on Capitol Hill about the unsustainable path the Medicare payment system is on, preventing further cuts means getting to the root causes of what’s wrong with Medicare physician payment.
That is why the AMA created the Medicare Basics series, which provides an in-depth look at important aspects of the Medicare physician payment system. With these six straightforward explainers, policymakers and physician advocates can learn about key elements of the payment system and why they are in need of reform.
Visit AMA Advocacy in Action to find out what’s at stake in reforming Medicare payment and other advocacy priorities the AMA is actively working on.
— Senior News Editor Kevin B. O’Reilly wrote an earlier version of this article.
