CMS’s Health Equity Framework and MIPS Implications
In April of this year, CMS released the Health Equity Framework for Medicare Advantage and the Merit-based Incentive Payment System (MIPS). CMS designed the Framework to improve healthcare for racial and ethnic minority populations. While we at ChirpyBird HIT are still digesting all of the Framework's implications, we believe several areas will significantly impact MIPS providers and their practice operations. This blog post will outline our thoughts on how the Framework could affect your medical practice.
Systemic racism is a pervasive problem in the healthcare industry. To combat this issue, the Centers for Medicare and Medicaid Services (CMS) promulgated a rule in 2021 that financially incentivized doctors receiving Medicare reimbursement to create and implement an anti-racism plan. The rule created a new improvement activity for providers that includes an enterprise-wide review of "existing tools and policies, such as value statements or clinical practice guidelines," demonstrating anti-racism and "an understanding of race as a political and social construct." This change is just one of several intended to achieve health equity that CMS has made to the Medicare Physician Quality Reporting System (MIPS). Through such initiatives, CMS hopes to address the systemic racism in healthcare and improve outcomes for all patients.
The CMS Health Equity Framework is designed to reduce disparities in health care quality and outcomes for racial and ethnic minority populations. The Framework aims to provide a standard set of measures for MA plans and MIPS eligible clinicians. Providers can use the measures to track and report progress in reducing healthcare disparities. The new Framework lays out five CMS priorities:
Expanding the collection, reporting, and analysis of standardized data
Assessing the causes of disparities within CMS programs and addressing inequities in policies and operations to close gaps
Building the capacity of healthcare organizations and the workforce to reduce health and health care disparities
Advancing language access, health literacy, and the provision of culturally tailored services
Increasing all forms of accessibility to health care services and coverage.
How tracking will work
The Framework sets goals for MIPS performance measures. For example, the new quality measure, "Adults Who screened for Colorectal Cancer," will reduce colorectal cancer screening disparities by 50% by 2024. This is a significant increase from the current MIPS target of 40%. To meet this new, more stringent goal, MIPS-eligible clinicians must ensure that they provide colorectal cancer screenings to their patients at the recommended frequency.
In addition, the Framework will also require MA plans and MIPS eligible clinicians to report on a new set of demographic information to track progress on reducing healthcare disparities. This new data collection will include questions on patients' race, ethnicity, primary language, and disability status.
We believe that the CMS Health Equity Framework will significantly impact MIPS providers and their practices. MIPS-eligible clinicians will need to be aware of the new quality measure targets and ensure they provide screenings and other services at the recommended frequency. They will also need to be prepared to collect and report on demographic information.
Challenges to the new rule
CMS's Health Equity Framework was created to help providers address health disparities among different racial and ethnic groups. However, at least two doctors have challenged the rule, arguing that the Biden administration has injected Critical Race Theory into a place where it belongs the least, namely, medicine. Admittedly, I did not expect to find this particular argument against the rule included in the opinion. It's particularly vexing when you consider that CMS does not require providers to create an anti-racism plan. Instead, CMS permits providers to pick among 106 improvement activities to earn bonus payments. CMS has defended the Framework, arguing that it is flexible and allows providers to tailor their approach to addressing health disparities. However, the challengers argue that CMS's approach is insufficient and that more needs to be done to address the root causes of health disparities. The case is still pending, and it remains to be seen how CMS will respond to these challenges.
If you have any questions about how the CMS Health Equity Framework will impact your MIPS participation, please contact us. We would be happy to help you navigate these changes.
