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As Deadline Nears, Healthcare Professional Associations Offer Comments to CMS on MACRA/MIPS

June 27, 2016
by Mark Hagland
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A host of healthcare professional associations submitted public comments to CMS about the MACRA-/MIPS-related proposed rule
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As the deadline neared for public comments on the proposed rule related to physician payment requirements under the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) legislation, which created the MIPS (Merit-based Incentive Payment System) system for physician reimbursement under Medicare, a host of healthcare professional associations released public statements that encompassed their comments to the federal Centers for Medicare & Medicaid Services (CMS).

The key elements in the various sets of comments included: a request that CMS officials delay the onset of the program from its proposed start of January 1, 2017, to July 1, 2017 or beyond; requests that CMS officials make major modifications to value-based concepts under MACRA; numerous types of requests for changes in the final rule around measurements and other elements in the MIPS program.

The American Medical Group Association (AMGA), the American Medical Informatics Association (AMIA), and the Premier health alliance, were among the numerous healthcare associations publicly sharing their comments to CMS.

In a June 27 letter to Andy Slavitt, CMS Acting Administrator, Donald W. Fisher, Ph.D., president and CEO of the Alexandria, Va.-based AMGA, suggested a very wide range of changes to the proposed rule, including a delay to the start of the program from January 1 to July 1 of 2017. Among those that touch on physician practice and health IT, Dr. Fisher said that AMGA wants CMS officials to rethink how they frame the use of healthcare it (HIT). With regard to the new Advancing Care Information (ACI) program, Dr. Fisher wrote, “Generally, the ACI measure still emphasizes the simple use of health information technology, i.e., competency in sending healthcare information electronically. The ultimate goal of the ACI measure is to improve care outcomes via measures that incent a business rationale for Certified Electronic Health Record Technology (CEHRT). CMS should evolve the ACI measure to reach this goal.”

Further, Dr. Fisher wrote, “The base score still includes Meaningful Use’s pass/fail methodology. AMGA proposes CMS award points for each base score measure reported… AMGA proposes CMS continue to use or apply previous meaningful use exclusions and hardships under MIPS ACI. AMGA also encourages CMS to align in the final rule ACI measures with the forthcoming Office of the National Coordinator’s (ONC’s) interoperability recommendations.”

Meanwhile, the Chicago- and Washington, D.C.-based American Medical Association’s James L. Madara, M.D., also sent a letter on June 27 to CMS’s Slavitt, with a host of recommendations that took 67 pages to be specified. Near the top of the letter, Dr. Madara summarized his many recommendations with the following bullet points. He urged CMS to:

>  “Establish a transitional period to allow for sufficient time to prepare physicians to have a successful launch of MACRA.

>  Provide more flexibility for solo physicians and small group practices, including raising the low volume threshold.

>  Provide physicians with more timely and actionable feedback in a more usable and clear format.

>  Align the different components of MIPS so that it operates as a single program rather than four separate parts, such as creating a common definition for small practices.

>  Simplify reporting burdens and improve chances of success by creating more opportunities for partial credit and fewer required measures within MIPS.

>  Reduce the thresholds for reporting on quality measures.

>  Reward reporting of outcome or cross-cutting measures under a bonus point structure rather than a requirement in order to achieve the maxium quality score.

>  Improve risk adjustment and attribution methods before moving forward with the resource use category.

>  Replace current cost measures that were developed for hospital-level measurement and refine and test new episode measures prior to widespread adoption.

>  Permit proposals for more relevant measures, rather than keeping the current MU Stage 3 requirements.

>  Remove the pass-fail component of the Advancing Care Information (ACI) score).

>  Reduce the number of required Clinical Practice Improvement Activities (CPIAs) and allow more activities to count as “high-weighted.”

>  Simplify and lower financial risk standards for Advanced APMs.”

With regard to the measurement of physician performance under the entire program, the AMA wants CMS officials to provide real-time feedback to practicing physicians. “We appreciate CMS’s efforts to conduct MIPS user assessments but are concerned these efforts fall short and do not address the complexity of accessing feedback reports,” Dr. Madera wrote to Slavitt. “We are also concerned with the timeliness of the release of feedback reports and benchmarking information. CMS should consult with stakeholder groups to determine the best presentation and most meaningful format for sharing ongoing, actionable performance feedback with physicians and practices. As technology is constantly changing,” he noted, “it is critical that CMS take an ongoing approach to improving he way performance information is dismmenatied to physicians and practices…” Rather, he wrote, “[W] encourage CMS to move towards a more iterative process where physicians and vendors submit data more routinely to CMS.”

AMIA Weighs In on Clinical Practice Improvement Activities (CPIAs)