FAIRFAX, Va. (June 28, 2016)— The Society of Interventional Radiology (SIR) submitted comments to the Centers for Medicare and Medicaid Services (CMS) recommending changes to the April 27 Quality Payment Program proposed rule.
“We appreciate CMS’ considerable effort in developing the proposed rule, and believe that, with some modifications, a workable solution for patients and interventional radiologists can be achieved,” said SIR President Charles E. Ray Jr., an interventional radiologist, professor and chair of the department of radiology at the College of Medicine at the University of Illinois at Chicago. “Several aspects of the rule, as proposed, could have negative consequences for patients’ access to and choice of care.”
“We are concerned that the proposal’s arbitrary thresholds regarding who reports on all four aspects of the Quality Payment Program and the mechanisms and timelines for reporting may actually work against the intent of the Medicare Access and CHIP Reauthorization Act,” Ray said. “Rather than providing increased access to innovative, quality care for all patients, the reporting burdens and restrictions may reduce access to care, particularly in rural and underserved areas.”
Under the rule, physicians who fall below arbitrary thresholds comprised of total billed Medicare charges and total Medicare patients seen, or a yet-to-be defined list of patient-facing procedures, will either be excluded from the Merit-based Incentive Payment System (MIPS) or required to report on fewer MIPS measures. SIR believes a potential, unintended consequence of these low thresholds is that patient access to low-complexity but critical IR services in some practices will be limited, particularly in smaller groups and rural communities. These practices have historically used the group practice reporting option (GPRO) to simplify the administrative burden of measure reporting under current quality measurement system.
“The rules proposed for GPRO under MIPS take an all or nothing approach for reporting,” Ray explained. “We are concerned that there could be an impetus for groups whose physicians meet different thresholds to limit access to important patient-facing, interventional radiology services needed in the community simply because of the reporting requirements. This is not good for patients.”
SIR recommended that CMS raise the threshold to 100 encounters, allow for mixed reporting within a mixed group, and offer a two-year notice of change to allow clinicians the opportunity to adjust practice and reporting given that there is a two-year lag between performance and adjustment years.
In addition to having unintended consequences for patient’s access to an interventional radiologist’s care, SIR is also concerned that aspects of the rule make it difficult for interventional radiologists to accurately capture and measure quality across the breadth of care they provide.
SIR is recommending that CMS raise the cap on reporting measures contained in a single Qualified Clinical Data Registry (QCDR) and allow physicians to report across multiple QCDRs to measure quality. SIR believes this would incentivize a “team-based” approach to patient care and allow specialties like interventional radiology, which treat an array of conditions all over the body, to use a number of registries.
“To drive the best quality of care, physicians should be allowed to measure themselves against metrics specific to the procedures they’re performing,” said Ray. “However, practitioners are currently limited to reporting through a single QCDR and that registry is capped to only 30 quality measures.”
SIR will launch its IR Registry in late 2016 within the American College of Radiology’s National Radiology Data Registry (NRDR). CMS’s restrictions around QCDRs will make it difficult to cover the scope of interventional care in one registry.
“Given the breadth and variety of practice within interventional radiology, our members need a sufficiently wide variety of measures from which to choose in order to meaningfully and accurately report on their performance,” Ray said. “This flexibility of defining measures in a QCDR is complementary to the annual call for MIPS measures and would increase the likelihood that interventional radiologists would be able to report on quality measures meaningful to the Medicare patient population they treat.”
For details about each of SIR’s recommendations, please view our full comment letter available here.