AMGA urges CMS to lower MIPS exclusion threshold

AMGA on July 5 revealed its support for lowering the exclusion thresholds in the Medicare Access and CHIP Reauthorization Act's Merit-Based Incentive Payment System.

AMGA's support comes on the heels of a July 3 letter sent by five members of the House GOP Doctors Caucus to CMS Administrator Seema Verma.

In the letter, the members of Congress called on CMS to ensure the MIPS rule for performance year 2019 "provides adequate incentive to encourage providers to invest in the infrastructure needed to deliver care that achieves the quality and cost goals set forth in MACRA."

The lawmakers note MACRA adjusted Medicare Part B payments "based on performance measured against a threshold score," and Congress authorized $500 million more in the law "to further incentivize participation" and "ensure positive payment adjustments for all providers that met the benchmark." MACRA allows providers to earn an adjustment of up to 7 percent on their Medicare Part B payments in 2021 based on the 2019 performance year, according to AMGA.

However, the lawmakers said "the program relies in part on meaningful participation in the program and the current regulations have reduced these payment incentives by excluding many providers from participation." Overall, they said they are concerned "that the low-volume thresholds are too high and effectively preclude providers from earning more than a nominal payment adjustment."

Lawmakers cite a CMS estimate showing that about 60 percent of otherwise eligible clinicians are excluded from MIPS for the 2018 performance year based on the existing participation threshold.

In a statement, AMGA officials said this creates a problem for high performers, including AMGA members.

"This prevents high performers … from earning the payment adjustment authorized under MACRA, as the exclusions effectively collapse the MIPS payment adjustment distribution curve," the officials said. "As a result, the payment adjustment of up to 5 percent for 2018 performance instead is projected to be 1.5 percent for high performers. CMS has an opportunity to adjust the low-volume thresholds in the regulation for 2019 so more remunerative updates are possible. Lowering the thresholds would more fully realize Congress' intention for MIPS to move Medicare toward a value-based system."


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