AMIA Sees Complexity, Opportunity in New Physician Payments Rule

Monday, June 27, 2016

Evidence-based focus, additional time will be ‘imperative’ if new reforms are to work, informatics experts say

(BETHESDA, MD) — In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the nation’s leading clinical informaticians urged federal officials to seize the “unique opportunity to reimagine policy levers” for multiple federal programs meant to improve care quality, cost and outcomes. Officials from the American Medical Informatics Association (AMIA) supported much of the proposals included as part of Medicare’s new Quality Payment Program (QPP) but voiced serious concerns over the rule’s timing. AMIA also outlined several principles CMS should consider during implementation of the largest physician payment overhaul in a generation.

CMS announced in April new proposals to combine several federal programs into a single QPP for physicians and other clinicians paid through Medicare. The QPP is composed of quality, resource use, technology and practice improvement requirements, and establishes two main pathways for physicians to receive payment: through a Merit-based Incentive Payment System (MIPS) or through an assortment of Alternative Payment Models (APMs), such as Pioneer ACOs. Beginning in 2019, clinicians paid through Medicare will receive bonuses or penalties based on a composite score in MIPS, or they will be subject to the risk-sharing terms of their APM.

"We applaud CMS for proposing a set of policies and requirements across the four categories of MIPS and for Alternative Payment Models that clearly incorporate stakeholder feedback and lessons learned from the legacies of the Physician Quality Reporting System, Value-Based Modifier, EHR Incentive Program, and various alternative payment models,” AMIA said in comments. “AMIA believes CMS has an unprecedented opportunity to learn which components of these legacy programs will effectively support our healthcare system in moving toward the triple aim, and we strongly recommend that CMS engage medical informatics expertise more broadly to understand how technology should be leveraged to improve care experience, expense and efficacy."

However, AMIA also expressed doubt over the ability of clinicians to successfully participate in a full-year reporting period beginning January 1, 2017.  "AMIA recommends CMS issue an interim final rule with a comment period to further refine proposed policies based on stakeholder feedback, and we recommend CMS consider a 90- or 180-day reporting period in 2017." The organization said success in the first year would be critical to the long-term success of the reforms.

In order to improve the current proposal and to help guide future proposals, AMIA established several principles CMS should consider related to QPP, which included:

  • Use data reporting requirements to learn, not simply to grade.
  • Focus on defining clear, expected outcomes, rather than prescriptive process measures.
  • Engage organizations and experts to perform scientifically rigorous, peer-review studies to determine which requirements should be retained in future years.
  • Develop feedback loops that are accurate, timely and meaningful.
  • Encourage increased data exchange and interoperability whenever possible.

"CMS has been tasked with changing our fundamentally flawed fee-for-service Medicare reimbursement system, and has issued an ambitious set of proposals to do so” said AMIA President and CEO Douglas B. Fridsma, MD, PhD, FACMI. “While the new Quality Payments Program is complex, we are hopeful that these policies will enable informatics to play a central role in lowering costs, improving quality and delivering better outcomes."

Specifically, AMIA supported the newly conceptualized Clinical Practice Improvement Activities (CPIAs) Performance Category and proposed a number of enhancements to the proposed Advancing Care Information (ACI) Performance Category, which will replace Meaningful Use for clinicians participating in MIPS. AMIA recommended CMS emphasize CPIAs that leverage team-based and transdisciplinary care, and encouraged CMS to score maintenance of certification IV activities with a "high" weighting to take advantage of robust continuing medical education programs already in place. AMIA also recommended CMS reinstitute exclusion criteria for certain ACI Performance Category measures, and asked CMS to reconsider how they calculate the ACI Performance Score to give clinicians additional flexibility to focus on meaningful IT functionalities.

"AMIA has a strong interest in seeing the ACI Performance Category work for all stakeholders, and I foresee clinicians demonstrating tremendous innovation to achieve credit for the CPIA category," said AMIA Board Chair and Medical Director of IT Services at the University of Washington’s UW Medicine, Thomas H. Payne, MD, PhD, FACMI. “While imperfect, these proposals will give clinicians the tools they need to track progress on quality, improve resource use and utilize informatics to deliver better care for patients."

Click here for AMIA’s full response to CMS proposals.


AMIA, the leading professional association for informatics professionals, is the center of action for 5,000 informatics professionals from more than 65 countries. As the voice of the nation’s top biomedical and health informatics professionals, AMIA and its members play a leading role in assessing the effect of health innovations on health policy, and advancing the field of informatics. AMIA actively supports five domains in informatics: translational bioinformatics, clinical research informatics, clinical informatics, consumer health informatics, and public health informatics.