The ACR is taking steps to clarify a proposed rule from the Centers for Medicare and Medicaid Services (CMS) that, as currently written, would consider the cost of Part B drugs when calculating physician reimbursement under the Merit-Based Incentive Payment System (MIPS).
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“The ACR is concerned about this, because large cuts to reimbursement for pass-through items, such as Part B drugs, would severely limit the viability of our members’ practices,” says Angus Worthing, MD, FACR, FACP, chair of the ACR’s Government Affairs Committee (GAC).
What It Means for You
MIPS is one of two reimbursement pathways established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), bipartisan legislation that replaced the Sustainable Growth Rate and consolidated such reporting programs as Meaningful Use and the Physician Quality Reporting System.
Beginning in 2019, provider payments will be subject to a 4% positive or negative adjustment depending on scores across several performance categories, increasing to plus or minus 9% by 2022. MIPS is budget neutral, which means half of providers realize bonuses while the other half see penalties.
In the 2018 Quality Payment Program Proposed Rule issued by the CMS in June 2017, the agency indicates that “items and services” furnished by MIPS-eligible providers, including the cost of Part B drugs, would be subject to adjustment.1
“Receiving a minus 4 to minus 9% payment based on Part B drug costs could be catastrophic to a rheumatology practice, forcing rheumatologists to no longer infuse drugs in-office, or it could bankrupt a practice,” says Kayla Amodeo, PhD, ACR Regulatory Affairs director.
For example, professional charges for seeing a patient with rheumatoid arthritis in-office four times a year are $433.52, Dr. Worthing told Inside Health Policy in September. A one-year course of Remicade at a starting dose costs a physician practice $11,328.85. The MIPS penalty or bonus, then, would be applied to the $11,762.37 per patient charge, rather than the $433.52 alone.2
In fact, a resolution introduced in the American Medical Association House of Delegates by the American Society of Clinical Oncology and the ACR estimates the median financial impact for some specialties could range from 16–19%.3
Rheumatologists are among the most active providers of Part B drugs, Dr. Worthing says. “If rheumatologists close their doors, their patients would lose access to critical treatments.”
A Shift in Policy
In a letter to the Department of Health and Human Services written by Reps. Erik Paulsen (R-Minn.) and Leonard Lance (R-NJ), on which they were joined by over two dozen colleagues in the U.S. House of Representatives, the lawmakers wrote that the proposed rule represents a shift in policy for the CMS, given that the reporting programs it replaced did not factor Part B costs into reimbursement.4