The Society of Interventional Radiology (SIR) submitted comments to CMS regarding the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) proposed rules, saying the rules could have “unintended consequences for access to care, quality.”

“We appreciate CMS’s considerable effort in developing the proposed rule, and believe that, with some modifications, a workable solution for patients and interventional radiologists can be achieved,” Charles E. Ray Jr., MD, PhD, SIR president, said in a prepared statement. “Several aspects of the rule, as proposed, could have negative consequences for patients’ access to and choice of care.”

One concern the SIR shared was that, since physicians falling below “arbitrary thresholds” could be potentially excluded from the Merit-based Incentive Payment System (MIPS), access to “low-complexity but critical IR services in some practices” could be limited in smaller groups and communities in rural or underserved areas. Practices in these areas usually take advantage of the group practice reporting option (GPRO), the SIR said in its comments,

“The rules proposed for GPRO under MIPS take an all or nothing approach for reporting,” Ray said in the statement. “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.”

Raising the threshold to 100 encounters, permitting mixed reporting and providing clinicians with a two-year notice of change are ways SIR suggested CMS could address this issue.

The society also expressed concern that what CMS has proposed would make it harder for interventional radiologists to “accurately capture and measure quality across the breadth of care they provide.” To address this issue, SIR recommended CMS raise the cap on reporting measures in a single Qualified Clinical Data Registry (QCDR) and allow physicians to report measures across more than one QCDR.

“To drive the best quality of care, physicians should be allowed to measure themselves against metrics specific to the procedures they’re performing,” Ray said in the statement. “However, practitioners are currently limited to reporting through a single QCDR and that registry is capped to only 30 quality measures.”

The full SIR comments can be read on its website.