Saturday, June 24, 2017

Brief Blog: MIPS/MACRA Rulemaking for 2018 Published; Rapid Coordination of Doctor Metrics & Patient Benefits

CMS released CY2018 MIPS/MACRA rulemaking on June 20, 2018.

  • CMS press release, here.   
  • CMS 26 page summary of rulemaking, here.
  • Trade journal article here.
  • The official Federal Register version appeared June 30, here.
    • Federal Register, 6/30/2017, 82 FR 30010-30500 (490 pp).
  • Comment period runs to August 21, 2017 [60 days].
  • For an update on "physician payment reform" in general, in NEJM July 2017, here.
CMS Proposes Simultaneous Prevention Benefit (DPP) and Matching Metrics to Encourage Physician Awareness


For those tracking CMS's new prevention initiative beginning in 2018, the Diabetes Prevention Program (DPP), CMS proposes to rapidly interweave its physician metrics with its newest healthcare initiative.  (For an entry point see collected links here).   CMS proposes to add two metrics which measure (1) referral of appropriate at-risk patients to DPP and (2) whether patients enroll in DPP.   The two measures are proposed in the Physician Practice Improvement metrics section, rather than in the Quality of Care section (which carries forward PQRS type metrics).   

It's often stated that US healthcare, including Medicare, pays short shrift to prevention [*] and that physicians are slow to adopt new interventions recommended by guidelines and bodies like the USPSTF.   By rapidly incorporating new Medicare preventive benefits into the physician reward and penalty metrics, CMS seems to be integrating efforts across its domains and silos and the agency should be commended for that.  Here, the new metrics for physician referral behavior and the new preventive services for at-risk beneficiaries will appear simultaneously, whereas it wouldn't have been surprising if the metrics had lagged by five years and had appeared as an afterthought.

Appropriate Use Criteria Get a Call-Out

PAMA law required the creation and use of Appropriate Use Criteria and Clinical Decision Support for advanced imaging orders.  (CMS home page here, my November 2016 blog here).   This is spurring the creation of a mini-industry in response.  Early adopters of imaging AUC in CY2018 can get credit in a proposed metric.  (Full required use will be phased in later).     Depending on the success of the radiology AUC program, it's not impossible that Congress could replicate the requirement for other areas, like genomics, in a future year.   This would benefit the emerging laboratory benefit management (LBM) industry.   (Appropriate Use Criteria also get quite a bit of discussion the July PFS rulemaking, here).

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[*]  Healthcare reform legislation in House and Senate in June 2017, for example, proposes to defund a couple billion dollars for U.S. preventive care such as vaccinations.

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Downsides of MIPS/MACRA - Skeptical Voices.   E.g. this June 2017 blog, "Drop MACRA!" here.  For a June 2017 blog on whether integrating (or force-feeding) evidence based medicine recommendations into EHRs works or not, here.

  • For articles and blogs about problems caused by MIPS/MACRA, just google the three words MIPS MARCA PROBLEMS, or click here. Typical title, "Is the Metrics Cure Worse Than the Disease?" 
  • Similarly, even the federal Medicare watchdog committee MEDPAC didn't have much good to say about MIPS in June 2017 in their report to Congress -  here