The American Society of Anesthesiologists submitted a formal comment to CMS in response to the 2018 Quality Payment Program Final Rule on the Medicare Access and CHIP Reauthorization Act.
Here's what you should know:
1. ASA feels anesthesiologists do not have "ample opportunities" to participate in or succeed in the Merit-based Incentive Payment System or in Advanced Alternative Payment Model pathways as the rule currently stands.
2. ASA asked CMS to modify three key elements.
First, ASA wants CMS to post future QCDR measures by Dec. 1, prior to the reporting year. ASA believes practices need sufficient time to update data collection processes to prepare for new measures.
Second, ASA would like CMS to use the upcoming year to refine facility-based measures both internally and externally. In a statement, ASA wrote, "CMS must better detail how hospital quality scores will be translated into MIPS Quality and Cost scores and how will eligible clinicians and their practices be informed that they have met the threshold for choosing the facility-based reporting option."
Finally, ASA wants CMS to reconsider how it approves advanced payment models to include specialty physicians and larger patient populations.
3. The ASA also included a comment on the quality measure reporting threshold. ASA wants to lower data completeness to 50 percent of applicable cases.
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