MGMA submits telehealth policy recommendations to Congress

This week, MGMA submitted written testimony to the Subcommittee on Health of the House Committee on Energy and Commerce’s hearing on “The Future of Telehealth: How COVID-19 is Changing the Delivery of Virtual Care” for consideration as they begin discussing policies that would expand telehealth flexibilities beyond the COVID-19 pandemic. MGMA's testimony outlined certain policy recommendations to consider while drafting legislation. MGMA believes any future legislation expanding Medicare telehealth should:

• Preserve the patient-physician relationship to promote high-quality care,
• Remove geographic and originating site restrictions,
• Allow permanent coverage of audio-only services, and 
• Reimburse telehealth visits equally to in-person visits.

CMS applies automatic MIPS hardship policy for 2020

Following MGMA advocacy, the Centers for Medicare & Medicaid Services (CMS) announced it will automatically apply the MIPS extreme and uncontrollable circumstances exception policy to all MIPS eligible clinicians for the 2020 performance period due to the COVID-19 public health emergency (PHE). This policy applies to individuals and groups that are unable to submit sufficient 2020 MIPS data during the submission period.

Additionally, the agency is reopening the 2020 hardship application portal through March 31, 2021. Physicians, groups, and alternative payment model (APM) entities may submit an application to reweight one or all MIPS performance categories due to the COVID-19 PHE. Submitting MIPS data in two or more categories, such as quality and improvement activities, will override a hardship exception on a category-by-category basis.

2020 MIPS hardship exceptions: Consider the COVID-19 impact on cost measures

Some physician practices may be able to and wish to report 2020 MIPS data, for example, to earn an exceptional performance bonus by reaching the 85 point threshold. In light of CMS’ announcement to reopen the MIPS hardship application portal, MGMA encourages groups, including those who have submitted or plan to submit MIPS data, to consider submitting an application to reweight the cost category to zero. The deadline to submit data and hardship applications is March 31.

MIPS cost measures are calculated automatically based on claims data and have no reporting requirement. However, we have concerns that cost measures will be significantly impacted by the COVID-19 PHE. Those approved for reweighting of the cost performance category pursuant to an application will never be scored on cost measures and the category will be reweighted to zero. Our concerns about cost measures include:

• Because cost measures rely on national average benchmarks, physicians and practices in hot spots may have higher costs than the national average.
• Postponing preventive and routine care may skew patient attribution toward the sickest patients.
• Inadequate risk adjustment methodologies during a pandemic may severely affect patients who face economic hardships and social risk factors.

Lack of transparency into cost measure scoring, attribution, and benchmarks.

MGMA and ASTRO urge refinements to radiation oncology APM

MGMA partnered with the American Society for Radiation Oncology (ASTRO) in a letter voicing concerns about the radiation oncology (RO) APM. The letter sent to the Biden administration highlights that the RO model is overly focused on achieving cost savings at the risk of jeopardizing access to care and quality. MGMA will work with the new Administration to achieve shared goals of value-based care and encourages transparency and an open dialogue in model development going forward.