Concerning the proposed updates to the Relative Value Units (RVUs), the ACR recognizes that CY 2022 is the final year of a four-year transition period to update the practice expense (PE) component with the latest pricing data for supplies and equipment. In conjunction with this final year of the equipment pricing update, CMS is also proposing an update to the clinical labor pricing component in CY 2022, which could result in temporary distortions for provider reimbursement. To minimize disruptions to physician practices, the ACR recommends CMS use a similar four-year transition to implement the clinical labor pricing update.
EHR Interoperability & Digital Quality Measures
While the ACR is overall encouraged by CMS’ efforts to broaden the standardization of clinical data and increase electronic health record (EHR) interoperability, the ACR has several concerns with how the agency’s proposed recommendations will impact practices – particularly smaller practices with fewer financial resources. As a next step for moving forward, the ACR recommends CMS conduct an environmental landscape assessment of EHR software capabilities that should consider factors such as costs to practices, specialty-specific templates and reports, registry participation and patient portal access. This should help establish a clearer picture of practices’ reasonable ability to meet CMS’ proposed digital health goals and avoid a situation where providers are held accountable for factors that are beyond their control.
Rheumatology MIPS Value Pathway (MVP)
The ACR is pleased that the proposed rule includes a new MIPS Value Pathway (MVP) for rheumatology as proposed by the ACR and looks forward to working with the agency to ensure that it is implemented successfully. However, the ACR has several concerns with the proposed rollout of the MVP program and the lack of details that have been provided thus far. In particular, the ACR recommends delaying setting a deadline for sunsetting traditional MIPS until the agency can evaluate the success of implementing MVPs.
For more details, view the ACR’s full comment letter.
