The Texas Medical Association is "very concerned that many of the compliance, documentation, and reporting requirements that will be implemented in the future Medicare system are wasteful, costly, and do little or nothing to improve care quality or increase efficiency," TMA President Tom Garcia, MD, told the Centers for Medicare & Medicaid Services (CMS).
The strong comments came in response to a CMS request for information regarding implementation of the Merit-Based Incentive Payment System (MIPS), promotion of alternative payment models, and incentive payments for participation in eligible alternative payment models. CMS published the proposal for implementation in the Federal Register on Oct. 1.
"The requirements and incentives may even have the counterproductive effect of reducing access to good ambulatory care for some or all Medicare beneficiaries. If the goal is to reduce total medical cost, it is counterproductive to try to achieve that by increasing the total cost of medical practice. If the goal is better use of ambulatory care by patients, it is counterproductive to penalize the physicians who provide it," Dr. Garcia wrote.
In developing rules to implement MIPS, TMA urges CMS to consider these principles:
- They must be administratively efficient, keeping new documentation and reporting requirements to an absolute minimum. When possible and relevant, documentation should be drawn from existing sources such as claims data or Medicare enrollment records.
- Physicians should be held accountable only for those aspects of cost and quality that they can reasonably influence or control.
- Physician choice of payment model should be preserved. No physician should be forced or coerced into accepting a payment model that is unacceptably risky for small practices, which are likely to have a small and unrepresentative patient mix.
- All quality and meaningful use measures should be revised to exclude the effects of patient care preferences or choices and patient inability or unwillingness to adhere to medical orders or advice.
- All cost or utilization measures should be revised so that they do not cause adverse impact on physicians who treat patients from any socioeconomic, racial, or cultural group which may have diverse preferences for medical treatment.
For a full list of TMA's recommendations, read the letter.
Action, Dec. 1, 2015