Anatomy IT Advocates for MIPS and ASCQR Clients: Urging CMS to Improve Patient and Physician Experience

September 18, 2024

Anatomy IT asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting programs in comments submitted on both the 2025 Quality Payment Program (QPP) and the 2025 ASC Quality Reporting Program (ASCQR) proposed rules. See our previous blogs for a summary of the proposed changes to the QPP and the ASCQR in 2025.

Quality Payment Program Comments

In our response to the 2025 QPP Proposed Rule, we focused on problems that our clients currently face under MIPS and anticipated problems with proposed changes.

  • In the Quality section:
    • We continued to advocate for our specialty and subspecialty clients. While CMS has proposed scoring adjustments to certain measures to more fairly assess specialty practices, there remains a lack of relevant measure options, particularly at the subspecialty level. We emphasized the need for a comprehensive set of specialty- and subspecialty-specific measures to accurately reflect the quality of care delivered by these providers.
    • We supported CMS’ proposal to maintain the 75% performance threshold through 2028 but expressed concerns about the plan to increase the threshold in future years.
    • We requested that CMS add an exception for all outcome measures in cases where a patient within the eligible population passes away prior to the end of the outcome window.
  • In the Improvement Activities (IA) section:
    • We advocated for small practices by encouraging CMS to maintain special scoring in future years.
    • We welcomed and supported CMS’ proposal to simplify the scoring process for this category by assigning equal points to each IA and requiring practices to attest to a fixed number of IAs.
  • In the Promoting Interoperability (PI) section:
    • We thanked CMS for proposing the solution to the multiple PI submissions problem that we have long advocated for in comment letters and discussions. Beginning with data from the 2024 performance year, CMS will no longer assign a 0 if multiple scores are submitted and will, instead, assign the highest of those scores.
    • In response to the request for feedback on the Public Health and Clinical Data Exchange objective, we urged CMS to avoid overburdening clinicians. We recommended that HHS focus on improving the infrastructure of state public health agencies, rather than attempting to use the MIPS PI category to achieve modernized data exchange infrastructure.
  • In the Cost section:
    • We advocated for increased transparency in measure development, more substantive information in feedback reports, and greater clarity in measure specifications.
    • We urged CMS to implement specialty attribution exclusions for episode-based cost measures to ensure that only clinicians directly responsible for the care of a condition or procedure are assigned the associated costs. This would mirror the exclusions in the Total Per Capita Cost (TPCC) measure. Similarly, we requested that NPs and PAs no longer be exclusively labeled as primary care, as this subjects specialty-only practices with these providers to the TPCC measure at the group level.
    • We supported CMS’ proposed revision of the cost measure scoring methodology. The new approach will include standard deviation to reduce the negative impact of small variations in episode costs.
  • MIPS Value Pathways (MVPs):
    • We opposed CMS’ plan to “sunset” traditional MIPS in 2029 (or in any future year), as we believe a fee-for-service model will always be valuable, and because we do not believe that MVPs will be applicable to specialists in the timeline CMS is anticipating.

ASCQR Comments

In this proposed rule, CMS introduced three new measures to improve health equity.

Screening for Social Drivers of Health (SDOH)

This measure was proposed as voluntary for 2025 but mandatory for 2026. It would require clinicians to ask their patients questions about SDOH. While we strongly support the advancement of health equity, we have concerns about this measure in its current form. Addressing SDOH requires resources that are best developed by government agencies, as this responsibility goes beyond the scope and capacity of clinicians. Requiring clinicians to screen patients for SDOH without providing the necessary resources to address these issues could damage the provider-patient relationship, compelling patients to disclose their vulnerabilities without receiving adequate support. In our response to the 2025 ASCQR Proposed Rule, we opposed this measure, urging CMS to rethink its approach and ensure that patient safety remains the primary focus.

Screen Positive Rate for SDOH

This measure was also proposed as voluntary for 2025 but mandatory for 2026. As with the Screening for SDOH measure, we opposed this measure because it would require asking patients sensitive questions about SDOH without providing clinicians with the resources to address any issues identified.

Facility Commitment to Health Equity (FCHE)

The FCHE measure was proposed to be mandatory in 2025 and would require SDOH screening in certain domains. Given our concerns about screening for SDOH without sufficient resources to address them, we recommended either making this measure voluntary or limiting it to non-screening domains.

Next Steps

  • Watch our webinar on the 2025 MIPS proposed changes.
  • Review our Top 2025 Proposed MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.
  • Subscribe to our blog using the field in our website footer below. When the finalized rules are released later this Fall, you’ll be among the first to know what new MIPS and ASCQR requirements will be in store. If you want hands-on, personalized assistance on MIPS or the ASCQR, contact us and we will have your back.

Sarrah Hakim, MHSAWritten By: Sarrah Hakim, MHSA

About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.

Posted in MIPS, ASCQR, blog