ASA strongly supports Congress’ work to repeal, once and for all, the flawed Medicare Physician Fee Schedule Sustainable Growth Rate (SGR) formula. The SGR formula, the mechanism that annually updates Medicare payments to physicians and other healthcare professionals, has for years threatened to penalize the nation’s front line health care providers with payment cuts that, at times, reached in excess of 20 percent. Fortunately for Medicare beneficiaries and the program, Congress has consistently acted with “doc fixes” to prevent the implementation of the draconian cuts – cuts that would have been unsustainable, particularly to a specialty like anesthesiology. ASA is grateful for the bipartisan, bicameral work of Congress to permanently strike this onerous payment mechanism.
With repeal of the SGR formula, this legislation represents the first step toward a new physician payment structure. While we support elimination of the SGR threat, ASA maintains a “no position” or neutral stance on the new payment structure - a new structure built around programs known as the “Merit-Based Incentive Payment System”, or MIPS program, and the “Alternative Payment Model” (APM) program. The MIPS and APM programs create possible pathways to positive payment adjustments – payment increases - for physicians providing services to Medicare beneficiaries. Physicians who are able to successfully engage the necessary resources and navigate the MIPS program will be eligible for as yet undefined positive payment adjustments, while those who participate in APMs are eligible for payment increases of five percent. ASA is pleased that the legislation includes a number of provisions sought by ASA that may help physician anesthesiologists to fully and successfully participate in these new programs. These include a meaningful role and financial support for specialty societies, such as ASA, to advance specialty-endorsed quality measures to Medicare and a series of provisions intended to strengthen and support Qualified Clinical Data registries (QCDRs), such as the Anesthesia Quality Institute’s (AQIs) National Anesthesia Clinical Outcomes Registry (NACOR). Additionally, we believe the APM program offers ASA the opportunity to introduce anesthesiology-related payment models such as the ASA Perioperative Surgical Home.
With these basic structures in place, ASA has also identified elements that will require additional attention as implementation moves forward. The central focus for ASA will be working to help physician anesthesiologists to succeed under the new MIPS program. Our work will include efforts to advance relevant and attainable quality measures for the specialty and to gain improvements to the Value-Based Payment Modifier (VBM) program. The challenges that physician anesthesiologists continue to face regarding participation in the Meaningful Use (MU) program will also need to be addressed. Additional work will be required to assure participation in AQI’s qualified clinical data registry, NACOR. Beyond the MIPS program, ASA will also work to advance APMs suitable for physician anesthesiologists’ participation. ASA efforts to secure inflationary updates will continue, as will efforts to address the longstanding inequity in Medicare payment levels for anesthesia services.
ASA congratulates Congress for its work to abolish the SGR formula. We look forward to working with Congress and the Centers for Medicare and Medicaid Services (CMS) moving forward to play a meaningful role in helping to shape the implementation of this new payment structure.