In an overwhelming display of support for the value of continuing medical education (CME), over 300 stakeholders submitted comments to the Centers for Medicare and Medicaid Services (CMS) suggesting the agency should adopt new incentives to motivate physicians to participate in CME activities.
FOR IMMEDIATE RELEASE
Contact: Andrew Rosenberg, (202) 247-6301, [email protected]
Several hundred leading healthcare practitioners, plus scores of stakeholder groups representing millions of the nation’s healthcare providers, submitted comments in support of encouraging the use of accredited CME to improve the quality of healthcare under the new Merit-Based Incentive Payment System (MIPS), according to analysis conducted by the CME Coalition. Over 300 endorsements for CME were submitted in response to CMS’ call for public comment on implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), including comments from leading physician groups, CME providers, and other stakeholders.
Under the new MACRA law, physicians who do not participate in a qualifying alternative payment models (APM) will be subject to adjustments under MIPS. MIPS is based on a 100-point score, with clinical practice improvement activities (CPIA) representing 15 percent of the score. In their numerous comments to CMS, stakeholders asserted that CME should be included in the CPIA measurement category, as these courses are among the most effective ways for doctors to improve their understanding of new treatments and therapies, improve patient outcomes, and ultimately, improve their practice as a whole.
“Participation in professional development activities like CME results in meaningful, sustained clinical performance improvement,” said Andrew Rosenberg, Senior Advisor to the CME Coalition. “This overwhelming demonstration of support for including CME in these new value-based assessments demonstrates the clear consensus of healthcare stakeholders that CME plays a pivotal role in improving the practice of medicine.CME COALITION COMMENTSThe CME Coalition submitted comments on June 27 addressing both the practical and technical implications of including CME in the CPIA measurement category under MIPS. “Consistent with the intent of [MACRA], and with focus on the ‘three aims,’ the National Quality Strategy (NQS) and the CMS Quality Strategy, CME encourages physicians to develop and maintain the knowledge, skills, and practice performance that leads to improved performance with optimal patient outcomes,” the comments state. “Simply put, without translating the new payment system into meaningful actions for physicians, the promise of MACRA will never be fully achieved.”
The Coalition’s comments go on to detail the need for physicians to participate in CME to remain informed of the evolving landscape of treatment options and quality measurements. “Without this professional development, the measurement of adherence to quality metrics and use of health information technology are insufficient to produce clinical performance improvement,” the Coalition explains. “Patients will continue to need health care professionals that engage in lifelong learning, assessment, and improvement in practice, so it is important these activities be recognized and rewarded in value-based payment programs promulgated by CMS and private payers.”
COMMENTS FROM CME ACCREDITING BODIESAccreditation Council for Continuing Medical Education
“Specifically, the ACCME requests that: (1) CMS recognize relevant performance and quality improvement accredited continuing medical education (CME) as a clinical practice improvement activity within MIPS. (2) CMS designate ACCME’s Program and Activity Reporting System (PARS) as a reporting mechanism for clinical practice improvement activities.”
Accreditation Council for Pharmacy Education (ACPE)
“We recommend that CMS explicitly acknowledge and provide credit for certain CE (as well as CME) activities, provided by a nationally-recognized accreditor, as clinical practice improvement activities within the Merit-Based Incentive Payment System. In specific, we seek explicit credit for certain defined CE activities in two of the CMS designated clinical practice improvement activities, namely: (1) Accredited CE activities that involve assessment and improvement of patient outcomes or care quality, as demonstrated by clinical data or patient experience of care data, such as Quality Improvement CE. (2) Accredited CE that teaches the principles of quality improvement and the basic tenets of MACRA implementation, including application of the ‘three aims,’ the NQS, and the CMS Quality Strategy, with these goals being incorporated into practice.”PROVIDER GROUP COMMENTSAmerican Medical Association
“First, we would like CMS to add accredited continuing medical education (CME) and board-certification related activities to the list of CPIAs. These activities take up considerable time for physicians but ensure patient care is of the highest quality and reflects the latest medical knowledge and innovations. While 45 some proposed CPIA activities could be satisfied through CME, we believe a more explicit recognition would help physicians understand whether all CME will count under the CPIA component of MIPS.”
American Academy of Family Physicians
“Aligning with CPIAs is performance improvement CME, which supports health care transformation by encouraging clinicians to reflect on current practice and engage them to make changes in their practice that ultimately improves the care that is delivered. There are now multiple examples in the literature that proves the value of performance improvement CME as a vehicle for not only promoting change, but also embedding that change into a practices’ workflow so that observed improvement is sustained in the long term. Fundamentally, the objectives of CPIAs and performance improvement CME are congruent with the strategic goals of the Administration.”
Council for Medical Specialty Societies
“[W]e strongly urge CMS to specifically recognize accredited continuing medical education (CME) as another means to satisfy CPIA requirements. CME encourages physicians to develop and maintain the knowledge, skills, and practice performance that leads to improved performance with optimal patient outcomes. Practice improvement multi-dimensional interventions, including participation in professional development activities like CME, are a necessary component of the change process that results in meaningful, sustained clinical performance improvement. Without this professional development, the measurement of adherence to quality metrics and use of health information technology are insufficient to produce clinical performance improvement.”
Alliance for Continuing Education in the Health Professions
“I am the 2016 President of the Alliance for Continuing Medical Education, the largest national organization of educational professionals dedicated to the continuing education needs of physicians and other healthcare professionals. Like so many other respondents to this call for comments, we know from many years of evidence-based research that CME (continuing medical education) that is designed to involve clinicians in efforts to make changes to the systems of care and the behaviors that are represented in those systems does lead to significant clinical changes that benefit patients.”
MORE ORGANIZATIONAL COMMENTSAlong with over 300 individuals who submitted comments on CME and MIPS, the following organizations also submitted comments on CMS’ proposal:
FOR IMMEDIATE RELEASE
Contact: Andrew Rosenberg, (202) 247-6301, [email protected]
Several hundred leading healthcare practitioners, plus scores of stakeholder groups representing millions of the nation’s healthcare providers, submitted comments in support of encouraging the use of accredited CME to improve the quality of healthcare under the new Merit-Based Incentive Payment System (MIPS), according to analysis conducted by the CME Coalition. Over 300 endorsements for CME were submitted in response to CMS’ call for public comment on implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), including comments from leading physician groups, CME providers, and other stakeholders.
Under the new MACRA law, physicians who do not participate in a qualifying alternative payment models (APM) will be subject to adjustments under MIPS. MIPS is based on a 100-point score, with clinical practice improvement activities (CPIA) representing 15 percent of the score. In their numerous comments to CMS, stakeholders asserted that CME should be included in the CPIA measurement category, as these courses are among the most effective ways for doctors to improve their understanding of new treatments and therapies, improve patient outcomes, and ultimately, improve their practice as a whole.
“Participation in professional development activities like CME results in meaningful, sustained clinical performance improvement,” said Andrew Rosenberg, Senior Advisor to the CME Coalition. “This overwhelming demonstration of support for including CME in these new value-based assessments demonstrates the clear consensus of healthcare stakeholders that CME plays a pivotal role in improving the practice of medicine.CME COALITION COMMENTSThe CME Coalition submitted comments on June 27 addressing both the practical and technical implications of including CME in the CPIA measurement category under MIPS. “Consistent with the intent of [MACRA], and with focus on the ‘three aims,’ the National Quality Strategy (NQS) and the CMS Quality Strategy, CME encourages physicians to develop and maintain the knowledge, skills, and practice performance that leads to improved performance with optimal patient outcomes,” the comments state. “Simply put, without translating the new payment system into meaningful actions for physicians, the promise of MACRA will never be fully achieved.”
The Coalition’s comments go on to detail the need for physicians to participate in CME to remain informed of the evolving landscape of treatment options and quality measurements. “Without this professional development, the measurement of adherence to quality metrics and use of health information technology are insufficient to produce clinical performance improvement,” the Coalition explains. “Patients will continue to need health care professionals that engage in lifelong learning, assessment, and improvement in practice, so it is important these activities be recognized and rewarded in value-based payment programs promulgated by CMS and private payers.”
COMMENTS FROM CME ACCREDITING BODIESAccreditation Council for Continuing Medical Education
“Specifically, the ACCME requests that: (1) CMS recognize relevant performance and quality improvement accredited continuing medical education (CME) as a clinical practice improvement activity within MIPS. (2) CMS designate ACCME’s Program and Activity Reporting System (PARS) as a reporting mechanism for clinical practice improvement activities.”
Accreditation Council for Pharmacy Education (ACPE)
“We recommend that CMS explicitly acknowledge and provide credit for certain CE (as well as CME) activities, provided by a nationally-recognized accreditor, as clinical practice improvement activities within the Merit-Based Incentive Payment System. In specific, we seek explicit credit for certain defined CE activities in two of the CMS designated clinical practice improvement activities, namely: (1) Accredited CE activities that involve assessment and improvement of patient outcomes or care quality, as demonstrated by clinical data or patient experience of care data, such as Quality Improvement CE. (2) Accredited CE that teaches the principles of quality improvement and the basic tenets of MACRA implementation, including application of the ‘three aims,’ the NQS, and the CMS Quality Strategy, with these goals being incorporated into practice.”PROVIDER GROUP COMMENTSAmerican Medical Association
“First, we would like CMS to add accredited continuing medical education (CME) and board-certification related activities to the list of CPIAs. These activities take up considerable time for physicians but ensure patient care is of the highest quality and reflects the latest medical knowledge and innovations. While 45 some proposed CPIA activities could be satisfied through CME, we believe a more explicit recognition would help physicians understand whether all CME will count under the CPIA component of MIPS.”
American Academy of Family Physicians
“Aligning with CPIAs is performance improvement CME, which supports health care transformation by encouraging clinicians to reflect on current practice and engage them to make changes in their practice that ultimately improves the care that is delivered. There are now multiple examples in the literature that proves the value of performance improvement CME as a vehicle for not only promoting change, but also embedding that change into a practices’ workflow so that observed improvement is sustained in the long term. Fundamentally, the objectives of CPIAs and performance improvement CME are congruent with the strategic goals of the Administration.”
Council for Medical Specialty Societies
“[W]e strongly urge CMS to specifically recognize accredited continuing medical education (CME) as another means to satisfy CPIA requirements. CME encourages physicians to develop and maintain the knowledge, skills, and practice performance that leads to improved performance with optimal patient outcomes. Practice improvement multi-dimensional interventions, including participation in professional development activities like CME, are a necessary component of the change process that results in meaningful, sustained clinical performance improvement. Without this professional development, the measurement of adherence to quality metrics and use of health information technology are insufficient to produce clinical performance improvement.”
Alliance for Continuing Education in the Health Professions
“I am the 2016 President of the Alliance for Continuing Medical Education, the largest national organization of educational professionals dedicated to the continuing education needs of physicians and other healthcare professionals. Like so many other respondents to this call for comments, we know from many years of evidence-based research that CME (continuing medical education) that is designed to involve clinicians in efforts to make changes to the systems of care and the behaviors that are represented in those systems does lead to significant clinical changes that benefit patients.”
MORE ORGANIZATIONAL COMMENTSAlong with over 300 individuals who submitted comments on CME and MIPS, the following organizations also submitted comments on CMS’ proposal:
- Advanced Dermatology Associates – Pennsylvania
- American Academy of Allergy Asthma and Immunology
- American Academy of Neurology
- American Academy of Physical Medicine and Rehabilitation
- American Association of Neurological Surgeons
- American Board of Medical Specialties
- American College of Physicians
- American College of Rheumatology
- American Medical Informatics Association
- American Osteopathic Association
- American Society for Radiation Oncology
- American Society of Gastrointestinal Endoscopy
- American Society of Nephrology
- American Urogynecologic Society
- American Urological Society
- California Academy of Family Physicians
- Endocrine Society
- Medical Society of New Jersey
- Rockpointe Corporation
- Society for Academic CME
- Society of Nuclear Medicine and Molecular Imaging
- Society of Vascular Surgery
- South Carolina Medical Association
- Trauma Care Association of America
- Washington State Medical Society
