The Centers for Medicare & Medicaid Services (CMS) should revise its proposed system for updating physician payment rates to reward physicians for appropriate use of medical imaging and for using telehealth to foster more coordinated care. The agency should also adjust its proposal to reduce the risk of underutilization of medical imaging.
These were among the Philips comments in response to the April, 2016, CMS proposal for implementing the new physician payment system that Congress passed last year, called the Medicare Access and CHIP Reauthorization Act, or MACRA. The CMS proposal detailed the elements of physician performance that it would consider in setting rates for the portion of MACRA that most physicians would fall under—the Merit-Based Incentive Payment System, or MIPS.
- Telehealth: Philips said that telehealth offers Medicare significant opportunity for a more coordinated, integrated care system—especially for better managing patients with multiple chronic conditions—but that the CMS proposal interprets telehealth only as a replacement for face-to-face, in-person physician visits. Thus, physicians who use telehealth in its broader capacity do not get rewarded in the payment updating process. Philips urged CMS to recognize the value of such utilization, especially in remote management of chronically ill patients, and to reward physicians who use telehealth in this way.
- Imaging: Philips encouraged CMS—in establishing its rate-setting methodology—to credit physicians with providing imaging services in accredited facilities and with incorporating appropriate use criteria in the quality review systems of such facilities. At the same time, Philips urged CMS to correct elements of its proposal that might fail to recognize—or that might even encourage—underuse of imaging. It also urged Medicare to not apply net health outcomes measures to diagnostic imaging in light of the myriad other intervening factors, beyond diagnosis, that can influence the final patient health outcome.
The Philips comments apply to the proposed rate-calculation process that CMS would use in factoring-in a physician’s performance on quality and cost metrics.