On June 20, the Centers for Medicare and Medicaid Services (CMS) released its proposed rule for performance year 2018 of the Quality Payment Program (QPP), a new program that significantly changes the way that PAs and other clinicians are paid under Medicare Part B. The draft regulation includes a recommendation from PAEA to reward clinicians eligible for the QPP “Merit-Based Incentive Payment System” (MIPS) if they serve as preceptors for clinicians-in-training, as well as help them achieve a positive Medicare payment adjustment. CMS’ proposal specifically highlights the training of PAs in clinical rotations in community practices in small, underserved, or rural areas.
The Medicare Access and CHIP Reauthorization Act of 2015 created the QPP, and — beginning this year — the program incentivizes higher value, quality care provided by PAs and other clinicians, including physicians, advanced practice registered nurses, and others who care for Medicare patients. To gain credit toward a positive MIPS payment adjustment, eligible Medicare Part B providers are required to participate in several practice improvement activities in performance year 2018 and future years.
In March 2017, PAEA’s Government Relations team submitted a proposal that CMS designate precepting as a practice “Improvement Activity” (IA) under MIPS beginning in 2018. In the proposed rule issued by CMS, the agency accepted this proposal. Importantly, they also designated the provision as a high-value improvement activity, meaning that it would count more toward a clinician’s overall MIPS score because it has “the greatest impact on beneficiary care, safety, health, and well-being.”
PAEA President William Kohlhepp, DHSc, PA-C, hailed the move as a “major milestone in PAEA’s efforts to address the clinical site shortage faced by PA programs.” He went on to say, “This proposed rule, if adopted, will make significant progress toward incentivizing preceptors to train PA students in their practices.”
In March — as a follow-up to a substantial PAEA study of the issues confronting PA clinical training and with endorsement from the Board of Directors — the PAEA Government Relations team submitted an IA Performance Category in response to a CMS solicitation. The proposed IA is titled “Education for Quality Improvement — Training New PA Learners in Quality and Value for Future System Impact.” Driving the submission was the hope that it will motivate practicing clinicians to accept PA students for clinical rotations.
Clinicians and practices that embrace active quality and value efforts provide a crucible for innovation. It is vital that Medicare incentivizes these individuals and institutions to train students so that graduates of PA programs are prepared to address the unique needs of Medicare patients. Dividends for this improvement in the QPP will accrue in the future practices of PA graduates, many of whom work in underserved areas, as they introduce and implement the improved quality and outcome measurement programs they were exposed to during their training.
CMS has requested public comments on the proposed rule by 5:00 p.m. on August 21. We encourage all program directors and faculty to submit comments in support of the proposed rule, specifically 42 CFR Part 414.
In the coming weeks, the Government Relations team will be distributing follow-up information about how you can have your voice heard in support of PA clinical sites.