On February 5, 2021, Your Academy delivered comments to The Centers for Medicare and Medicaid Services (CMS) in response to the Episode Based Cost Measures: Wave 4 Cost Measure Development comment opportunity.
CMS has contracted with Acumen, LLC, to develop episode-based cost measures for potential use in the Merit-based Incentive Payment System (MIPS). Under MIPS, eligible clinicians receive a performance-based adjustment to their Medicare payments based on a final score that assesses evidence-based and practice specific data in 4 performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability.
CMS identified 4 clinical areas with 7 priority episode groups for consideration of development in Wave 4. These clinical areas were selected based on discussions with CMS regarding the criteria for measure prioritization with an emphasis on previous stakeholder input. One of the areas of consideration is Therapy and Rehabilitation. This clinical area would represent a new measure framework focusing on the care and treatment provided by physical therapists and related specialties for broad conditions such as Low Back Pain or both Low Back and Neck Pain.
Your Academy conveyed to CMS that physiatrists are often responsible for the creation and implementation of comprehensive care plans for patients with low back pain. We advocated that our members can offer key insights into the development of a measure in this clinical area and encouraged the inclusion of PM&R in any steps for the development of a low back pain cost measure.
More information on the Episode Based Cost Measures can be found on www.qpp.cms.gov.