Under the new MACRA Merit-Based Incentive Payment System (MIPS) that took effect this year, physicians get points towards their composite MIPS score based on participation in clinical practice “improvement activities.” Although there are over 90 approved “improvement activities” to choose from, none are specific to allergy practices. To change that, the College, together with the AAAAI and the AAOA, requested that CMS create a new “improvement activity” for allergen extract preparation. Physicians that follow specialty practice parameter guidelines in preparing allergen extracts would qualify for MIPS “improvement activity” points which could help obtain a positive payment adjustment under Medicare. This would be in addition to USP 797 Sterile Compounding rules that are already required in many states.
If CMS approves our request, this will allow allergists, beginning in 2018, to receive MIPS points for voluntarily following the guidelines published in the Allergen Immunotherapy Practice Parameters. Those guidelines go beyond current USP rules in several respects including the requirement that mixing personnel review the detailed extract preparation manual, pass the allergen extract quiz and complete an annual media fill test. They also set forth specific percentages of phenol and glycerine to maintain bacteriostasis.
Under MIPS, clinical improvement activities count towards 15% of the physician’s composite score. We will keep you updated on whether CMS approves our request.