ASCP, AMA Urge Changes to CMS 2020 MIPS Measure Removal/QCDR Policies

ASCP recently joined with the American Medical Association (AMA) in voicing ongoing concerns with the Centers for Medicare and Medicaid Services’ (CMS) 2020 policies for qualified clinical data registry (QCDR) testing requirements and criteria for removal/acceptance of quality measures in the Merit-based Incentive Payment System (MIPS). The letter reflects concerns with policies finalized in the 2020 Quality Payment Program (QPP) Final Rule. ASCP also raised these viewpoints and others in a separate letter to the Agency on its proposed rule.

While ASCP has long supported reducing provider burden, promoting the use of QCDRs, and including high-value, meaningful measures in the QPP, we are concerned that pathologists and organizations developing quality measures are dis-incentivized to report through QCDRs or allocate resources to QCDR development. Measure development criteria are becoming increasingly stricter. As a result, ASCP argued that this could stifle innovation in measure development. Further, as policies and regulations constantly change, measure developers and providers alike are becoming frustrated with frequent program modifications. For example, CMS finalized a policy to remove measures from the MIPS program with low reporting rates only two years into the program. This arbitrary two-year cutoff fails to provide the time and resource allocation needed to adopt new workflows and standards to ensure measure adoption. This two-year mark also does not allow for ample data to be collected for benchmarking and tracking progress over time.

ASCP also expressed opposition to a new testing requirement that measures must be fully tested and validated prior to submission in the QCDR program. ASCP believes the new requirement will not provide sufficient time for measures developers to comply. This, ASCP opined, will stifle innovation in the QCDR measure development space as well as discourage participation in the QPP for physicians looking for new measures on which to report. In addition, the QPP measures currently included in the pathology measures specialty set are rapidly being removed due to their “topped out status” (measures nearing universal success are targeted for removal), so it is critical that QCDR measures be available to ensure pathologist reporting in QPP.

ASCP is committed to working with CMS to ensure a robust catalog of measures in the QCDR program and MIPS overall. We believe a robust measures set, coupled with regulations and policies that are consistent year to year are key to the success of the program. We also agree with the AMA that a specialty-specific approach to measurement is essential to ensuring optimal patient care. We are in alignment with the recommendations the AMA has put forth to make the timelines more feasible and lessen the burden of the new criteria finalized for the 2020 MIPS program. We will continue to monitor these policies and keep members apprised of developments as they arise.

Other articles in the February 2020 ePolicy News:

• ASCP’s Advocacy Yields Key Changes in NGS Coverage Policy
• ASCP, NSH Urge Anthem to Reconsider Reimbursement Cuts
• Virginia Legislature Working on Surprise Billing
• Gearing Up for the ASCLS Legislative Symposium
•  Choosing Wisely Champions Deadline Extended
• ASCP Seeking Effective Test Utilization Recommendations

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.