The American College of Rheumatology has called on CMS to “remove barriers” that it says hinder subspecialists and small practices from participating in alternative payment models. The organization issued its statement in the form of a comment letter in response to a CMS Innovation Center New Direction Request for Information.
“We believe the more rheumatologists who are able to participate in [alternative payment models], the more time they can spend with their patients managing their complex care needs, which will ultimately improve care quality and lower costs,” David Daikh, MD, PhD, president of the ACR, said in a press release. “To that end, we have recommended specific changes that would decrease the burden of financial risk on small practices and increase specialists’ participation in advanced [alternative payment models], specifically physician-focused specialty models and prescription drug models.”
As part of their response to CMS, the ACR included three recommendations:
Lower the payment and patient count thresholds used to determine “qualifying participant” status from 25% to 15%, and 20% to 10%, respectively, which, according to the ACR, will allow more rheumatologists to take part in in physician-focused alternative payment models while reducing financial risk;
Allow the set-up cost of physician-focused alternative payment models, including the cost of health record upgrades and employee training, to serve as the financial risk, at least on an interim basis, as the current risk criteria make it difficult for many physician-focused alternative payment models to achieve “advanced” status, an additional barrier to getting more rheumatologists to participate; and
Ensure that future models provide appropriate reimbursement for services provided by cognitive specialists, including non-face-to-face care and chronic disease care coordination, which help prevent costly and unnecessary procedures while lowering overall costs.
“We feel there are several pragmatic barriers to participation in an [alternative payment model] by subspecialists such as rheumatologists,” read the ACR’s comment letter, in part. “Many of these barriers are related to the fact that rheumatologists’ practices are small. This increases the burden of financial risk and reduces opportunities for economy of scale. In order to move significant numbers of physicians into [alternative payment models], the financial risk and patient thresholds must be reduced. We strongly suggest to CMS a proposal to lower the threshold for requirements to make ‘qualifying participant’ in an advanced APMs more achievable for smaller practices.”
According to the release, the ACR is currently developing its own arthritis-specific alternative payment model that will “address these concerns and serve as a template for future payment reform.” The model will be “based on flexibility in multiple domains” and encourage rheumatologists to adopt physician-focused models, the group said.
“As CMS continues to forge a new direction for [the Centers for Medicare and Medicaid Innovation], we encourage transparency throughout the process and strongly suggest any proposed new payment models go through the full public rule making process,” Daikh said in the release.
Disclosure: Daikh reports receiving grants from NIAMS and NIAID, as well as consulting fees or other remuneration from the American Board of Internal Medicine.