AAPC Comments on Quality-based Payment Proposed Rules

AAPC Comments on Quality-based Payment Proposed Rules

AAPC recently expressed  support of proposed rules for new quality-based payment for outpatient care from the Centers for Medicare and Medicaid Services (CMS); however, the organization of more than 155,000 coders, billers, auditors, and other healthcare business professionals  cautions a January 1, 2017 implementation date is too soon for providers to successfully implement changes.

AAPC Represents Members

AAPC’s CEO Jason VandenAkker made the comments in a letter to the CMS in response to proposed regulations for the Merit-based Incentive Payment System (MIPS), Alternative Payment Model (APM), and criteria for physician focused payment models, released via the Federal Register May 9. CMS’ proposed rule outlines the framework of payment reform authorized by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which makes three changes to how Medicare caregivers are paid:

Certified Professional Coder-Payer CPC-P

  • Ending the fretful Sustainable Growth Rate (SGR) formula for determining Medicare payments to healthcare providers;
  • Paying caregivers for better care rather than more care; and
  • Combining CMS’ existing quality reporting systems into one system.

“AAPC is optimistic about the opportunities MACRA execution allows to accomplish the goals of CMS, payers, eligible clinicians, technology vendors, and so many others,” VandenAkker wrote, also commenting on three points of CMS’ proposal:

First, the proposed rule requires clinicians to submit care episode groups, patient condition groups, and patient relationship categories for the report of data of and performance measure under MIPS. AAPC suggests CMS both respond to legitimate concerns of providers who found past regulations onerous, and use the new clinical and quality data to create electronic data interchange (EDI) and data capture standard similar to those already used for administrative data.

Second, AAPC supports the creation of a computer adaptive quality measure portfolio and believes measures should be a significant focus of the final rule. This includes portability of data. “The need to have portability of quality measures is a primary requirement for the administrative simplification of new payment models focused on value,” VandenAkker writes.

Third, AAPC is concerned with the timeline the proposal sets for providers to implement and be successful in reporting quality measures. The final rule, expected to be released in November 2016 and implemented January 1, 2017, gives little time for entities such as the NCQA, the Core Quality Measure Collaborative, and CMS to develop a computer adaptive quality measure portfolio. True interoperability, ongoing quality improvement, and performance measures require quality measure design, quality measure applicability, and successful quality measure reporting, and this is unlikely to happen in the timeline proposed.

A Lot, Very Fast

AAPC worries that implementing the workflows needed, especially if based on 2017 claims data when so many new ICD-10 codes are being introduced, sets up providers for frustration and failure. VandenAkker writes that ideally providers will need 18 to 24 months to identify, adopt, and apply measures to established workflows for meaningful data capture.

VandenAkker praised CMS for its development of the new rules, which regulators and providers both hope will solve a number of reimbursement, cost, and other problems in Medicare payment. “AAPC can only marvel at the efforts already made by CMS to translate MACRA legislation in this proposed rule,” he told the agency.

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Brad Ericson

Brad Ericson

Publisher at AAPC
Brad Ericson, MPC, CPC, COSC, has been publisher for more than nine years. Before AAPC he was at Optum for 13 years and at Aetna Health Plans before that. He has been writing and publishing about healthcare since 1979. He received his Bachelor's in Journalism from Idaho State University and his Master's of Professional Communication degree from Westminster College of Salt Lake City.
Brad Ericson

About Has 196 Posts

Brad Ericson, MPC, CPC, COSC, has been publisher for more than nine years. Before AAPC he was at Optum for 13 years and at Aetna Health Plans before that. He has been writing and publishing about healthcare since 1979. He received his Bachelor's in Journalism from Idaho State University and his Master's of Professional Communication degree from Westminster College of Salt Lake City.

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