Advocacy Update

March 21, 2019: National Advocacy Update

. 3 MIN READ

The AMA urged CMS to evaluate physicians in the Merit-based Incentive Payment System (MIPS) on episode-based cost measures that have a stronger correlation with costs that are within physicians' control and to remove the Total Per Capita Cost (TPCC) measure from MIPS, at least until significant issues with the measure are resolved. Necessary improvements include further validity testing, improved attribution methodology, increased reliability and the ability for physicians to review their data in a timely manner and make changes based on the data received.

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In response to concerns about TPCC, CMS recently undertook revisions to the measure. The AMA appreciates CMS' willingness to refine cost measures as problems are identified. However, the revised TPCC measure does not address underlying concerns about the measure's validity and raises new problems with the attribution methodology. The multi-stakeholder Measures Applications Partnership (MAP), which provides input to CMS on measures for use in performance-based payment programs, gave a recommendation of "do not support the revised TPCC measure with the potential for mitigation" for use in MIPS. It would be a bad precedent to move forward despite the MAP's recommendation or before the key issues identified with the TPCC measures are resolved.

In a letter dated March 6, the AMA urged the Office of the National Coordinator for Health Information Technology (ONC) and CMS to extend the comment period for two proposed rules on information blocking and health information exchange. Provisions in these rules will significantly impact interoperability and the way data is exchanged between patients, health providers, payers, technology developers and other health care stakeholders. Given the complex and interwoven nature of these rules, it is necessary for adequate time to provide comprehensive, thoughtful and detailed comments. The AMA is seeking at least an additional 30 days to comment.

In response to a hearing in the House on "Addressing the Public Health Emergency of Gun Violence," the AMA sent a letter asking that the Centers for Disease Control and Prevention (CDC) be granted $50 million to conduct epidemiological research on gun violence as part of the Fiscal Year 2020 appropriations process.

The AMA agrees that gun violence in the U.S., which accounts for 40,000 deaths annually, is a public health crisis, and research on this issue should be funded accordingly. Public health is focused on preventing disease and injury in communities and populations on a larger scale promoting public safety. However, the lack of federally supported research on the epidemiology of gun violence severely limits the ability of communities to implement effective interventions that would help stem the tide of gun violence. Determining the root causes of the problem through federally funded research is critical to developing solutions that could help stem the tide of gun violence.

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