Tag Archives: QPP

ACCC Comments to CMS on Quality Payment Program Proposed Rule

By Blair Burnett, ACCC Policy Analyst

On August 21, 2017, ACCC submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the agency’s proposed 2018 updates to the Quality Payment Program (QPP), a two-track value-based reimbursement system created by the Medicare Access and CHIP Reauthorization Act (MACRA). The two tracks in which eligible clinicians can opt to participate are the enhanced fee-for-service based Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), which require clinicians to take on more than nominal risk.

Under the QPP, 2017 performance will affect Medicare payments for all eligible clinicians in 2019. While many ACCC members have said they’re somewhat familiar with the program, others don’t feel quite as prepared to meet the specific program requirements.

In our comment letter, ACCC asked CMS for continued flexibility and additional clarity on how the MIPS adjustment will be applied in 2018. ACCC requested that:

  • CMS should continue to offer clinicians maximum flexibility in participating in the QPP, including through broad availability of alternative reporting options such as virtual groups, facility-based scoring, and MIPS APM reporting and scoring.

ACCC urges CMS to continue expanding the use of flexible reporting options that allow clinicians in diverse practices and communities across the country to participate in the QPP. Many ACCC practices are also currently participating in MIPS APMs, such as the Oncology Care Model (OCM), that do not currently qualify for the Advanced APM incentive outlined in the current proposal. ACCC advocates for more flexibility in what qualifies as an advanced APM and a continued flexible approach to allow clinicians to participate in the QPP to the best of their ability and in a manner that reflects the nature and priories of their practice and their patients.

  • CMS should finalize the increase in the low-volume threshold to $90,000 in Part B allowed charges and 200 Part B beneficiaries and clarify that the $90,000 threshold does not include the cost of drugs billed directly by clinicians.

ACCC supports increasing the threshold that exempts clinicians from the QPP based on a low revenue and patient volume because it allows practices with tighter resources to still successfully participate without fear of lower performance scores. We also ask CMS to clarify that the cost of the drugs billed directly by clinicians under Part B will not count towards the revenue threshold.

  • CMS should finalize its proposal to assign a weight of 0% to the cost performance category for CY 2018 and carefully implement the cost score in the future so that clinicians are assessed and scored against their peers and only for the costs of care for which they are responsible.

ACCC supports CMS’ proposal to delay scoring clinicians on cost for 2018 and urges CMS not to impose cost of care payment adjustments without accurate methodology. When considering how to assess cost under MIPS, we hope that CMS will: ensure fair beneficiary attribution for overall cost measures, establish narrowly tailored episode-based measures, apply its discretion  to reweight performance categories, and recognize the variable nature of costs through appropriate risk and specialty adjustments and exclusion of outliers.

  • Importantly, CMS should clarify that MIPS payment adjustments will not apply to Part B payments for drugs billed directly by clinicians.

ACCC strongly opposes applying the MIPS payment adjustment to Part B payments for drugs and urges CMS to clarify that the adjustment will not apply to drug payments. We are concerned that the application of MIPS adjustments to Part B drug payments would represent an unjustified change in agency policy, create incentives for clinicians to focus on cost of treatment rather than whether it is clinically appropriate, and create new barriers to access for patients.  

ACCC will update our membership when we see a final rule from CMS. Read our full comments.

Why It’s Important to Carefully Examine Your Practice’s 2015 PQRS and QRUR Reports

by Brittney Fairman, Policy Analyst, ACCC

Centers_for_Medicare_and_Medicaid_Services_logoOn September 26, 2016, the Centers for Medicare and Medicaid Services (CMS) made available the 2015 Physician Quality Reporting System (PQRS) Feedback Reports and the 2015 Annual Quality and Resource Use Reports (QRURs) for every group practice and solo practitioner nationwide. The reports identify providers by their Medicare-enrolled Taxpayer Identification Number (TIN), and reflect who satisfactorily reported data on quality measures under PQRS and, in the QRURs, how physicians performed in 2015 on the quality and cost measures used to calculate the 2017 Value Modifier. Importantly, these reports will determine whether a practice or solo practitioner will receive a bonus or negative payment adjustment in 2017.

In 2017, those who fail to meet the 2015 PQRS reporting requirements may be subject to a penalty of up to two percent, and practices may face a Value Modifier penalty of up to four percent when performance is compared to national quality and cost performance.

ACCC  encourages members to carefully examine these reports, particularly for inaccuracies, and contact CMS with any questions or concerns about perceived discrepancies. The window to request an informal review is September 26 – November 30, 2016. These reports are not automatically distributed, but must be accessed by authorized representatives from the CMS Enterprise Portal using an Enterprise Identity Data Management (EIDM) account established with CMS.

Reviewing these reports is particularly important in the context of new requirements under the Quality Payment Program (QPP) which will determine reimbursement based on similar measures starting in 2019.

If you are having trouble getting an adequate response from CMS after having contacted them about inadequacies in your PQRS or QRUR Report, please contact  Brittney Fairman at bfairman@accc-cancer.org.


For questions about the 2015 Annual QRUR, 2017 Value Modifier or how to request an Informal Review, contact the Physician Value Help Desk: Monday – Friday, 8:00 AM – 8:00 PM EST             Phone: 1-888-734-6433 (option 3);  Email: pyhelpdesk@cms.hhs.gov

For PQRS and EIDM questions, contact the QualityNet Help Desk:                                       Monday – Friday, 8:00 AM – 8:00 PM EST;  Phone: 1-866-288-8912 (TTY 1-877-715-6222);           Email: qnetsupport@hcqis.org