In the CMS 2027 Proposed QPP Rule, CMS proposed retiring the traditional MIPS reporting option after the 2028 performance period. Beginning with the 2029 performance period, clinicians who do not participate in a MIPS Alternative Payment Model (APM) would be required to report through the new MIPS Value Pathways (MVP) program. Practices that do not meet this requirement would receive up to a 9% reduction in Medicare payments.
Allergy/immunology remains one of the few specialties without a clinically appropriate MVP, making it difficult for allergists to meet this criteria. As a result, in our recent comments to CMS, the College advocated against sunsetting the traditional MIPS program and transitioning to mandatory MVP reporting. We also asked CMS to:
- Approve the previously proposed joint College-Academy allergy-specific MVP.
- Add meaningful allergy measures to existing ENT and Pulmonology Care MVPs.
- Allow cross-MVP reporting.
- At a minimum, protect clinicians from penalties when no applicable pathway exists.
To date, CMS has not approved any of our proposals to create an MVP pathway for allergy/immunology.
The College is grateful to the AMA and MGMA for highlighting the lack of an appropriate MVP for allergists in their recent QPP comments to CMS. Their support strengthens our case for a viable reporting pathway for allergy/immunology.
MGMA’s comments noted:
“While CMS believes that 98% of specialties will be covered by an MVP, this is likely an overestimate as numerous specialties, such as allergists, do not currently have an MVP applicable to them… In order to improve the program, CMS should work closely with medical groups and physician specialties to make sure the design of each MVP accurately reflects the reality of clinical care and is not forcing physician practices to report measures that are not clinically relevant.”
The AMA also highlighted the challenges facing allergists in its comments on MVPs:
“We recognize that CMS claims that 98 percent of specialties will be covered by an MVP if CMS finalizes the three new proposed MVPs. However, CMS must ensure that 100 percent of all specialties have a relevant MVP because MACRA mandates that all eligible clinicians are subject to MIPS. Therefore, it is imperative that CMS design a program that meets the needs of all specialties and subspecialties. For example, clinicians who specialize in allergy and immunology or radiation oncology do not have a relevant MVP, despite these specialties making several recommendations to CMS over the years.”
The CMS 2027 Final QPP Rule is expected to be released in early November. At that time, we will learn whether CMS accepted any of our proposed changes. We will continue to monitor this situation and advocate for a viable MVP reporting option for allergy/immunology.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
