MedPAC’s latest lead balloon

By Charles M. Lepkowsky, Ph.D.
May 30, 2018



Medicare Payment Advisory CommissionAt its Jan. 11 meeting, the Medicare Payment Advisory Commission (MedPAC) voted 14-2 to replace the Merit-based Incentive Payment System (MIPS) with the “voluntary value program” (VVP).

The medical community has already been abuzz with the news, including blogs to AMA membership about “MedPAC’s latest lead balloon,” and frank discussion of VVP’s impact on electronic health records (EHRs).

AMA and many of its regional and specialty affiliates have published extensively on the possible change from MIPS to VVPs. However, no information about VVP has been provided to psychologists by APA, APAPO or CAPP.

For several years, APA/APAPO/ CAPP have been encouraged to give pushback to CMS about value-based reimbursement models, including PQRS and now MIPS, which is apparently so flawed that MedPAC decided to terminate the program not even 13 months after it went “live.”

APA/APAPO/CAPP were also specifically cautioned by members against pushing psychologists to spend money and time contracting with APAPO’s partner, Healthmonix, to enroll in MIPSPro, because MIPS will not apply to psychologists until 2019, and will likely not apply to the vast majority of psychologists qualifying for the Medicare Low Volume Threshold Exemption rule.

It has also been observed (to no avail) that APAPO’s endorsement of a product sold by its business partner Healthmonix represents a potential conflict of interest.

Nonetheless, APA/APAPO/CAPP have encouraged psychologists to participate in value-based reimbursement programs, including PQRS and MIPS, and are promoting MIPSPRO to psychologists “in preparation” for 2019.

At the end of February, the leaders of APA/APAPO/CAPP were asked whether they planned to release information to APA members about VVP and, if so, when?

APA/APAPO/CAPP were also urged to examine closely VVP and write to MedPAC expressing concerns about value-based reimbursement and its consequences for access to and quality of care. Among these is VVP’s likely reliance on affiliation with an Accountable Care Organization for participation, which will automatically exclude most psychologists in professional practice.

At the end of February, APA’s Office of Regulatory Affairs responded: “Some providers may be excited to hear that Medicare Payment Advisory Commission (MedPAC) does not care for MIPS but it’s important to remember that it has no authority to start, alter, or close any federal programs.”

Perhaps, but CMS’s rapidly changing, sweeping programmatic changes in and out of PQRS, MIPS and possibly VVP over the past four years suggest that MedPac does indeed have significant direct influence on CMS policy.

APA’s response continued:

“Ironically, one of the reasons MedPAC cited in 2017 for eliminating MIPS is that it wanted to do so before providers were already receiving high positive adjustments.”

In other words, MedPac is concerned that compliance with MIPS allows providers of care actually to receive the incentive payments they earn. If this is true, it lends credence to the perception that CMS is more concerned with cost containment than quality of care delivery – one of the leading arguments against value based reimbursement models.

Finally, APA’s response stated:

“We are not ignoring the discussion of the Voluntary Value Program but at the present time we need to focus on what already exists and how it is likely to impact psychologists.”

Following this line of reasoning, it could be argued that the wait-and-see approach should also be applied to MIPS – e.g., waiting another year before encouraging professional psychologists to spend time and money enrolling in MIPSPro in order to prepare for a program which might or might not be implemented in 2019.

In contrast to the AMA’s active policy of informing its membership of practice-related issues and encouraging participation in decision-making, the message to psychologists by APA/ APAPO/CAPP is that they will let us know what they think we need to know when they think we need to know it.

This patronizing approach to withholding information from APA membership and making policy decisions in small, closed-door proceedings is exactly what led to the events culminating in the Hoffman Report. Despite the uproar that followed that report and promises of increased transparency, APA/APAPO/CAPP persist in this failed strategy.

Many APA members, including prominent psychologists who sought APA board positions, have left APA because they felt unheard, unrepresented and/or dismissed.

APA/APAPO/CAPP are engaged in a reorganization intended to address financial and organizational difficulties, but there has been no talk of providing more information or a larger role in decision-making to members.

Unless membership is provided more information and a meaningful role in decision-making, no reorganization is going to make APA relevant or viable in the future.

In fact, APA/APAPO/CAPP’s current reorganization represents an opportunity for every APA member to communicate these concerns directly to the leadership of what will soon be a singular organization nationally representing professional psychology.

APA members should send letters or emails to the leadership of CAPP and APAPO expressing a desire to be better informed and more included in the process of making decisions that directly impact our practices and the future of our profession.

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Charles M. Lepkowsky, Ph.D., is in private practice in Solvang, Calif. He is a past president of the Santa Barbara County Psychological Association and taught graduate psychology courses for 14 years. He may be reached at: clepkowsky@gmail.com.

 

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