AMGA Supports Lowering of MIPS Exclusion Threshold
Applauds Congressional Support for ‘Meaningful Participation

Alexandria, VA – AMGA applauds the support expressed by key members of Congress in a July 3 letter to Administrator Seema Verma on the need for the Centers for Medicare & Medicaid Services (CMS) to lower the exclusion thresholds in the Merit-Based Incentive Payment System (MIPS) so more clinicians can participate in the program.

In their letter to CMS, five members of the House GOP Doctors Caucus urged the agency to “provide meaningful incentive and opportunity” for providers to earn financial rewards for superior care. As authorized by the Medicare Access and CHIP Reauthorization Act (MACRA), providers have the opportunity to earn an adjustment of up to 7% on their Medicare Part B payments in 2021 based on their 2019 performance. However, the program relies in part on meaningful participation, and “current regulations have reduced these payment incentives by excluding many providers from participation.” The letter asserts that “the low-volume thresholds are too high and effectively preclude providers from earning more than a nominal payment adjustment.”

“As CMS develops its MIPS policies for the 2019 performance year, the agency can better tailor the program so that all providers are given the chance to succeed. We understand that CMS wanted to move cautiously when implementing the MIPS program, despite the fact that it is effectively a continuation of three pay-for-performance predecessor programs,” said  Jerry Penso, M.D., M.B.A., AMGA president and CEO. “Now that we are about to enter the program’s third year, it’s time to recognize that continuing to exclude a substantial percent of providers impedes moving the Medicare program to paying for value, which the Congress envisioned in overwhelmingly passing MACRA.”

Currently, CMS has excluded about 60% of otherwise eligible clinicians through the low-volume threshold. This prevents high performers, including AMGA members, from earning the payment adjustment authorized under MACRA, as the exclusions effectively collapse the MIPS payment adjustment distribution curve. As a result, the payment adjustment of up to 5% for 2018 performance instead is projected to be 1.5% for high performers. CMS has an opportunity to adjust the low-volume thresholds in the regulation for 2019 so more remunerative updates are possible. Lowering the thresholds would more fully realize Congress’ intention for MIPS to move Medicare toward a value-based system.

AMGA appreciates the support from key members of the House GOP Doctors Caucus and looks forward to working with them and the administration on continuing the transition to value-based care.


About AMGA
AMGA is a trade association leading the transformation of health care in America. Representing multispecialty medical groups and integrated systems of care, we advocate, educate, innovate, and empower our members to deliver the next level of high performance health. AMGA is the national voice promoting awareness of our members’ recognized excellence in the delivery of coordinated, high-quality, high-value care. More than 175,000 physicians practice in our member organizations, delivering care to one in three Americans.


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