The Advocacy Council recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) about a proposed Asthma/COPD cost measure in the Cost performance category of the Merit-based Incentive Payment System (MIPS). This measure will directly impact allergists participating in MIPS.
The Cost category of MIPS will make up 20% of the MIPS score in 2021 and is scheduled to increase annually, so it’s critical the new measure accurately reflects patient costs attributed to allergists. Cost measures are calculated using claims data, and no data submission is required from clinicians.
The College worked with a handful of allergy practices that downloaded field test reports for the Asthma/COPD cost measure to help answer the following questions:
- Are patients correctly attributed to providers?
- Are cost episode time periods for patients correctly defined?
- Are costs within each episode correctly attributed to providers?
In addition, the College assembled a workgroup of asthma experts to answer eight clinical questions related to the proposed measure.
In general, the College found the new cost measure to be overly complex and patient attribution to be sub-optimal. Some of our recommendations to CMS were as follows:
- CMS should delay implementation of this cost measure for at least a year to allow for further testing and review. During this period, the measure could be informational only, and affected physicians could have time to familiarize themselves with it. The COVID-19 pandemic has put enormous pressure on physicians, and those in areas impacted by the west coast wildfires are especially burdened. Introducing this complex measure during these stressful times seems ill-advised.
- Lung and thoracic surgery should not be included in the asthma subgroup since they are not related to asthma care.
- Nonspecific symptoms such as malaise, syncope, and chest pain should not be included as complications to differentiate the quality of asthma care provided.
- The patient attribution methodology needs to recognize that many patients are misdiagnosed by non-specialists as having asthma based on patient reported symptoms; however, when referred to a specialist, they are determined, based on pulmonary function testing (PFT) and other guidelines, as not having asthma. The costs of care for patients who do not have asthma or COPD should not be counted under this measure.
The Advocacy Council will continue to follow the review of this measure and advise you of its impact on allergists. The Advocacy Council – we have you covered!