On June 10, the American College of Physicians (ACP) sent a letter to the U.S. House of Representatives Energy and Commerce Committee (E&C) providing feedback on draft legislative language that the committee released on May 28. The language is meant to repeal the Sustainable Growth Rate (SGR) formula used for calculating Medicare payments to physicians and replace it with a fair and stable system, according to ACP.
The 20-page letter to E&C Chairman Fred Upton and Ranking Member Henry Waxman provides recommendations on questions that the committee raised on the two phases of the proposed legislation. The first phase would stabilize the payment rates under the current system while setting up a move to new payment models. The second phase would then transition away from fee-for-service and toward value-based models of payment with an update incentive program.
ACP stated that the legislation should:
- provide positive and stable payments to all physicians, with higher baseline updates for evaluation and management services, for at least five years;
- create a process for physicians to qualify for graduated incentive-based payments during this period of stability for participating in programs to improve quality and the effectiveness of care;
- put greater emphasis on programs that would move away from reporting on process measures at the individual physician level to programs that measure improvements in outcomes and patient experience with care at the organizational and system level;
- create a process to “deem” programs that would qualify for graduated incentive based payments;
- create a clearer “bridge” between the draft bill’s proposed fee-for-service competency-based incentive program and new payment models, by creating incentives within the competency-based update program for physicians who are developing the competencies needed within their practices and organizations to successfully make the transition to new payment and delivery models aligned with value;
- create incentives for physicians to develop and participate in “peer cohorts” that have the greatest potential to improve outcomes, patient experience and effectiveness of the care provided, at both an individual and organizational level and within their own communities;
- allow physicians in recognized patient-centered medical home (PCMH) practices to qualify for higher fee-for-service payments as early as next year; and
- create a timeline and process for the Department of Health & Human Services to evaluate, propose and designate approved new payment and delivery models, with hardship exemptions.
Additionally, ACP suggested that the committee needed to include additional, alternative payment models that could be considered for incorporation in a new Medicare system after the SGR repeal. These models should include the PCMH and PCMH Neighborhood; the “Prometheus” Evidence-informed Case Rate model; the Comprehensive Global Payment model; and the expanded use of bundled payments.
ACP also acknowledged that there may be some physicians who would be unable to transition away from the fee-for-service model of payment and that provisions for a hardship exemption should be made for those who could not make the transition through no fault of their own.
ACP President Molly Cooke, MD, FACP, writing on behalf of the College, concluded, “We support the intent of your proposal, and hope that our responses to the questions you posed will be of help to you in continuing the development of a proposal.”