The Society of Interventional Radiology (SIR) has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) recommending changes to the agency's proposed rule on its quality payment program.
Released on April 27, the rule proposes that physicians who fall below particular thresholds of total billed Medicare charges and total Medicare patients seen will either be excluded from the Merit-Based Incentive Payment System (MIPS) or be required to report on fewer MIPS measures, SIR said. The society cautioned that a possible unintended consequence of these thresholds is more limited access to low-complexity but critical interventional radiology services, especially in rural communities.
SIR recommends that CMS raise the threshold to 100 patient encounters and offer a two-year notice of change to allow clinicians to adjust practice and reporting, the society said. It is also recommending that CMS raise the cap on reporting measures for the Qualified Clinical Data Registry (QCDR) and allow physicians to report across multiple QCDRs.
"Given the breadth and variety of practice within interventional radiology, our members need a sufficiently wide variety of measures from which to choose in order to meaningfully and accurately report on their performance," SIR President Dr. Charles Ray Jr., PhD, said in a statement released by the society.
