On Sept. 13, ASCP submitted
comments on the Center for Medicare & Medicaid Services’ (CMS) Calendar Year 2022 Quality Payment Program (QPP) Proposed Rule. The comments, part of two comment letters submitted by ASCP on the Medicare Physician Fee Schedule Proposed Rule, focus on the Agency’s policy proposals for the QPP, including its two tracks: 1) the Merit-Based Incentive Payment System (MIPS) and 2) the Advanced Alternative Payment Models (APMs). In the letter, ASCP expressed concern about a number of issues impacting pathologists and their patients, including the following:
• Meaningful participation and overall applicability for pathologists in the QPP (MIPS and APMs alike);
• Consideration of the needs of pathologists, specialists and non-patient facing clinicians when making policy changes;
• Reduction of burdensome reporting requirements, especially for pathologists in small and/or rural practices;
• Support of the proposed Improvement Activities: Implementation of a Laboratory Preparedness Plan and Implementation of a Personal Protective Equipment (PPE) Plan as effective measures for current and future public health emergencies; and
• Stakeholder input in the development of a framework inclusive of all clinicians, given the difficulty that pathologists and other non-patient facing clinicians will have in participating in MIPS Value Pathways (MVPs) as they are currently constructed.
The goal of the MVPs is to move away from siloed activities and connect them across the Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA) categories. We believe that streamlining program requirements and connecting activities across these categories will be beneficial to participants, reduce burden, and is a change ASCP has advocated for in previous comment letters. ASCP raised concern, however, that the set of MVPs that go into effect in 2023 do not take into account non-patient facing providers, such as pathologists. Therefore, ASCP advocated for increased flexibility and meaningful participation for pathologists.
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.
To read more articles from this issue of ePolicy, click here. To learn more about ePolicy News and access past newsletters and articles, 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.
ASCP ePolicy News is supported by an unrestricted grant from Hologic.
