The American College of Cardiology (ACC) released an official comment on Aug. 21 in response to proposed updates to the Merit-based Incentive Payment System (MIPS) established with the Medicare Access and CHIP Reauthorization Act (MACRA).

Here are five key takeaways from the 22-page statement: 

1. Increasing the threshold for MIPS exemptions is a good idea.

For 2018, HHS and CMS proposed increasing the low-volume threshold from $30,000 or less in Medicare Part B charges or fewer than 100 beneficiaries to $90,000 or less in Part B charges or fewer than 200 beneficiaries.

“The ACC recognizes this is a substantial increase, but supports the change in order to ensure that all clinicians who are truly low-volume are eligible for the exemption,” the statement read.

CMS should routinely review the threshold, according to the ACC, to prevent a situation in which practices are vacillating from low-volume exemption to MIPS participation from year to year.

Notably, the ACC also supports CMS’s proposal to allow physicians to opt-in to MIPS participation even if they are otherwise exempt.

“This would promote CMS’s goal of ultimately tying all Medicare payments to a value-based payment program while preserving access to care for Medicare beneficiaries,” the ACC wrote. “The College also believes that there may be some clinicians and groups who have invested in meaningful practice transformation and want to be rewarded for their efforts regardless of the MIPS exemption.”

2. The ACC is in favor of CMS’s proposal for virtual group reporting—but suggests a later deadline period for election.

“Virtual groups will provide the opportunity for solo practitioners and small practices to report MIPS performance together, which will also encourage collaborative approaches to care and quality improvement,” the statement read.

But the window for forming these groups, the ACC believes, is too small. Formal agreements between each member of the group must be executed by Dec. 1, giving groups only a couple of months to complete the process.

The ACC suggested moving the deadline to the beginning of 2018, with the understanding that 90-day reporting periods for improvement activities and advancing care information will give late-forming virtual groups the flexibility to avoid a MIPs penalty.

3. MIPS bonuses and penalties could affect patient care.

“One unintended consequence is that the application of a MIPS penalty on top of the rising costs of drugs may limit the ability for clinicians to continue administering these therapies,” the ACC wrote. “Conversely, it also seems inappropriate for a clinician to receive a bonus on the cost of a Part B drug, which is not based on the value of the clinician’s service.”

4. A uniform, longer phase-out period for removing items from the improvement activities list is needed.

While the ACC noted the benefit of adding improvement activities to the 2018 list—including the PCI Bleeding Campaign—it believes removing other activities could penalize providers.

Regarding the proposed removal of the Million Hearts Risk Reduction Model, the ACC wrote: “CMS should maintain IA status for the Million Hearts model for all five years of the program or at a minimum, one additional year. Overall, the Agency should consider implementing a consistent, multi-year process for phasing out IAs.

“Like many IAs, the Million Hearts model encourages clinicians and groups to dedicate time and resources to the implementation of novel practices to improve patient care. In particular, the Million Hearts model requires participants to do this over a five-year period. Implementing a phase-out period would allow practices to better prepare for changes in IAs from year to year.”

5. The ACC believes early public reporting on Physician Compare could lead to misinterpretation.

Because of the flexibility offered in the first year of the Quality Payment Program (QPP), the amount of data reporting can vary from practice to practice.

This could cause some clinicians and groups to show they only met the minimum performance threshold, the ACC notes, when their level of care is no lower than that of a competitor with more fully reported data.

“CMS should consider how to best reconcile the value of public reporting with the risk of releasing data that can be misinterpreted,” the ACC wrote. “For this reason, the ACC strongly supports the proposal to provide clinicians and groups with a 30-day window for previewing their Physician Compare data and provide them with the opportunity to opt out of having their first-year performance data publicly reported.”