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ASCP Advocates for Meaningful Participation Under the QPP for Pathologists in 2020

Publication Date: Sep 27, 2019

ASCP submitted comments on CMS’s CY 2020 Quality Payment Program (QPP) Proposed Rule on September 24. The comments, part of ASCP’s comments on the Medicare Physician Fee Schedule, specifically addressed the Agency’s policy proposals for the QPP, including the two tracks: 1) Merit-Based Incentive Payment System (MIPS) and 2) Advanced Alternative Payment Models (APMs). In its letter, ASCP provided its perspectives and recommendations on issues impacting pathologists and their patients.

In its comments, ASCP urged the following:

Continued support of policies that reduce burden and encourage patient-centric care
Increased opportunities for pathologists and other non-patient facing clinicians to meaningfully participate in the four MIPS performance categories, APMs, and the newly proposed MIPS Value Pathways (MVPs)

Consideration of the challenges for specialists and non-patient facing clinicians (such as pathologists) when making changes to program requirements, particularly the Qualified Clinical Data Registry (QCDR) program

Acknowledgement of the National Pathology Quality Registry as a quality improvement tool for pathologists and the entire laboratory team to fulfill MIPS requirements

To provide an example, in our comment letter we provided support for MVPs, the new conceptual framework for the MIPS portion of the program that would begin in 2021. The goal of MVPs is to move away from siloed activities and connect activities across the Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA) categories. We believe that streamlining program requirements and connecting activities across disparate categories will be beneficial to participants and reduce burden, and is a change ASCP has advocated for in previous comment letters. We are concerned, however, that the MVPs as currently proposed do not take into account non-patient facing providers such as pathologists. It is unclear where pathologists might fit into this new scheme; therefore, we advocated for flexibility and meaningful participation for pathologists in our comments to CMS. Further, we expressed concern with proposals related to the QCDR program that could stifle innovation and make participation in the program more arduous for pathologists and specialty societies.

CMS is expected to release the QPP Final Rule later this year. We will keep our members informed on policy changes that impact pathologists and laboratory medicine.

Other articles in the October 2019 ePolicy News:

ASCP Delegation Meets with FDA on LDT Oversight
Fix PAMA, Don’t Change Laboratory Date of Service Rule, ASCP Urges CMS
ASCP Opposes E/M Proposal in Medicare Physician Fee Schedule
CDC Coordinates Investigation, Offers Healthcare Provider Resources Regarding Lung Disease Associated with Vaping
ASCP Expands List of Choosing Wisely Recommendations
Choosing Wisely Champions Recognized for Reducing Unnecessary Testing

To read more articles from ePolicy News click here.

For more information regarding ASCP's advocacy initiatives and policy positions, please contact ASCP's Center for Public Policy at (202) 408-1110.