Doctors to Congress: Keep Part B drug payments out of MIPS adjustment


Physician specialists are calling on Congress to isolate Medicare Part B drug reimbursements from payment adjustments under the Merit-Based Incentive Payment System (MIPS).

A coalition of medical societies, large group practices, and patient advocacy groups has asked for an “intervention this year with a technical correction that ensures the [MIPS] score adjustment is not applied to Part B drug payments,” according to Jan. 18 letter sent to the leaders of the Senate Finance Committee, House Energy and Commerce Committee, and the House Ways and Means Committee. “Since the 2018 MIPS year has begun, it is imperative that Congress acts quickly to ensure that patient access to critical treatments is not negatively impacted.”

Among the groups signing the letter are the American Academy of Dermatology, American Gastroenterological Association, American College of Rheumatology, American Academy of Neurology, and the American Society of Clinical Oncology.

Under MIPS, physicians are scored based on their performance across three categories: quality, improvement activities, and advancing care information. A fourth category, cost, is planned but not yet included in the score (although cost doesn’t impact adjustments until 2020, it is part of the 2018 program year). Medicare payments, which currently include Part B drug reimbursements, are subject to bonuses and penalties based on performance scores.

In their November 2017 update to the Quality Payment Program, which includes MIPS, officials at the Centers for Medicare & Medicaid Services said they would be moving forward with including Part B drug payments in the MIPS adjustment.

“This application of the adjustment ... is a significant departure from current policy and would disproportionately affect certain specialties,” according to the coalition’s letter.

Certain specialties, including rheumatology, oncology, and ophthalmology, have more to lose under the current policy because these specialists administer more Part B drugs than other specialists, according to health care consultancy Avalere Health.

For gastroenterologists, the primary concern with the application of the MIPS payment adjustment to Part B drugs is patient access to the biologics and biosimilars used to treat irritable bowel disease including Crohn’s disease and ulcerative colitis. Under CMS’s policy, gastroenterologists facing a penalty or negative payment adjustment may have Part B drug payments fall below what it costs to buy the Part B drug. Since Medicare payment for Part B drugs is based on average sales price (ASP), affected practices are more likely to be small, have a smaller number of patients on a Part B drug or prescribe a broader range of Part B drugs to patients. As MIPS payment adjustments increase each year the impact of the policy is expected to touch more practices and bring larger deficits further eroding access to the biologics and biosimilars used to treat inflammatory bowel disease.

“Certain specialists administer more Part B drugs than others and, therefore, may be exposed to significant financial risk and payment swings year-over-year under the CMS [Centers for Medicare & Medicaid Services] proposal,” John Feore, director at Avalere, said in a statement.

In 2018, physicians in those specialties could see drug payments increase or decrease by as much as 16%, according to Avalere research.

The policy likely will have an even greater effect on smaller practices and those in rural settings and could lead to access issues, according to the coalition letter.

“Some patients already face access challenges because the budget sequester has eroded reimbursements to physicians, and this policy would exacerbate these problems,” the letter states. “Patients would be left with fewer locations where they could receive care, resulting in less access and higher costs. A growing number of patients would then have to seek care in a hospital, which would result in higher out-of-pocket expenses and, particularly in rural communities, may require traveling longer distances to receive care.”

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