The AANS and the CNS recently submitted comments to the Centers for Medicare & Medicaid Services’ contractor, Acumen, LLC, regarding its re-evaluation of the Total Per Capita Cost (TPCC) measure currently in use under the Merit-based Incentive Payment System (MIPS). The TPCC measure evaluates the overall cost of care in both Medicare Part A and B provided to beneficiaries attributed to clinicians or groups throughout the MIPS performance year. Although the measure is intended to focus on primary care management and to exclude specialties that are not responsible for providing ongoing care, neurosurgeons are still often scored on the measure if they participate in MIPS as part of a larger, multi-disciplinary group practice. The current re-evaluation of the measure aims to address the accuracy of the measure’s current attribution methodologies.
The AANS and the CNS used this opportunity to point out the fundamental flaws of the TPCC measure, including its tendency to hold physicians accountable for costs outside of their reasonable control, its exclusive reliance on administrative claims data, its reliance on inadequate risk adjustment methodologies and its potential to create perverse incentives to undertreat patients.
