On September 28, 2022, more than 800 organizations and physician practices signed a letter to Congressional leadership, requesting that they extend the 5% incentive payment to advanced alternative payment models (APM) participants, currently scheduled to expire at the end of 2022. Advanced APMs is a track of the Quality Payment Program within Centers for Medicare and Medicaid Services (CMS) that offers incentives for meeting participation thresholds based on levels of payments or patients through the program. Providers that meet the thresholds become a qualifying APM participant.
Qualified participants receive additional benefits, including burden reduction and financial incentives, as well as exclusion from MIPS reporting and payment adjustments. Additionally, for performance years 2017 through 2022, qualified participants were able to receive a 5% APM incentive payment. However, that 5% incentive payment is scheduled to sunset this year and for performance years 2024 and beyond, qualified participants will be eligible for an increased physician fee schedule update based on the QP conversion factor.
In the letter, signatories noted that “a key aim of MACRA was to encourage physicians and other health care providers to transition into Advanced APMs” and MACRA provided the 5% incentive payment to “facilitate participation” in the models. A critical component of Advanced APMs is that they are focused on accountability, linking financial performance to quality and outcomes (instead of volume).
The letter notes that should be 5% incentive payment sunset as scheduled, it would “reduce reimbursements and serve as a disincentive to nearly 300,000 clinicians working to improve the quality and cost-effectiveness of care for millions of Medicare beneficiaries.” They even indicated it may “discourage future participation in models that have seen growing uptake in recent years.”
Further, the letter points to the investment that physicians and other health care providers must make to transition to Advanced APMs, spending on average $1 to $2 million annually on advanced care delivery tools. The Advanced APM incentive payments help to soften the blow of that investment requirement, allowing the providers to “reinvest in care transformation initiatives to benefits patients.”
The letter concludes by urging Congress to “include Section 4 of the Value in Health Care Act (H.R. 4587) in any end-of-year legislative package” which would extend the 5% Advanced APM incentive payments and allow CMS the authority to adjust thresholds to qualify for the incentive payments – currently scheduled for steep increases.
Comments
During the fall meeting of the National Association of ACO (NAACOS), a handful of ACO officials commented about the need for the incentive. Emily Brower, senior vice president of clinical integration and physician services for the hospital system Trinity Health called the incentive payment a “knowable, plannable, and countable dollar.”
CMS Administrator Chiquita Brooks-LaSure also supports the bonus payment, but notes it is up to Congress, saying “there are so many competing priorities in healthcare and across the government” and that the “ones that resonate are the ones that are going to really move the needle.”