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Will CMS Officials Heed Association Leaders’ Concerns on MIPS/MACRA, as We Surge Ahead Into the New Healthcare?

July 1, 2016
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Will senior CMS officials carefully consider association leaders’ major concerns on the proposed MACRA/MIPS requirements?

This week has been a week of intensified activity on the healthcare policy front. With just hours to go, numerous healthcare professional associations sent comments into senior officials at the federal Centers for Medicare & Medicaid Services (CMS), as the door was about to close for them to comment 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.

As Assistant Editor Heather Landi and I reported in separate articles this week, numerous comments came from such associations as the Englewood, Colo.-based Medical Group Management Association (MGMA), the Philadelphia-based American Academy of Family Physicians (AAFP), the Alexandria, Va.-based American Medical Group Association (AMGA), the Chicago- and Washington, D.C.-based American Medical Association (AMA), the Bethesda, Md.-based American Medical Informatics Association (AMIA), and the Charlotte-based Premier health alliance, among others.

The recommendations of these and other healthcare professional associations are quite diverse, and touch on a very wide range of issues. Fundamentally, they revolve around issues of timing and timeframes, many specific aspects of measurement of quality and outcomes, many IT-related requirements in the program, concerns over the program’s complexity, and concerns over the impact of the MIPS/alternative payment model participation requirements on small and rural providers.

As has been well-noted, the meaningful use program for physicians is being folded into the new MACRA/MIPS program, meaning that whether practicing physicians participate in an alternative payment model (APM) or in the MIPS program, the kinds of requirements that doctors faced under meaningful use will continue, in modified forms. What’s more, most of the measurements around healthcare IT, going forward, are focused on achieving success in broad areas that CMS officials have been pushing more generally: health information exchange and data exchange, care management and population health management, and patient engagement.

If there’s a single area in which nearly all of the associations agree on, it is their strong recommendation that CMS officials delay the onset of physician requirements from January 1, 2017, as referenced in the proposed rule, to at least July 1, 2017. As association leaders have pointed out in their comments, the January 1 start date obligating physicians to collect data for the Quality Payment Program, is one that healthcare professional association leaders almost universally believe would be too difficult for physicians to adhere to.

Meanwhile, among the statements made by association executives in their comments to CMS that most stood out, are the following:

Ø  Halee Fischer-Wright, M.D., the MGMA’s president and CEO, in her letter to CMS Acting Administrator Andy Slavitt, was openly critical along numerous dimensions. Among other things, she wrote that CMS’s “narrow definition of APM [advanced payment models] provides almost no opportunities for medical groups to begin the shift away from fee-for-service reimbursement,” and further, “strongly opposes” the overly-narrow and restrictive Advanced APMs criteria proposed by CMS,” she wrote in her association’s letter, adding that, “While MACRA established a requirement that APMs bear more than nominal financial risk, CMS would establish a rigorous risk standard that requires strict repayment of losses—a criterion that excludes the vast majority of legitimate APMs, such as Track 1 MSSP ACOs and the Bundled Payments for Care Improvement models.”

Ø  Meanwhile, the AMA’s CEO James L. Madara, M.D., offered a whole laundry list of requests/recommendations for Acting Administrator Slavitt, among them, that CMS “provide more flexibility for solo physicians and small group practices, including raising the low volume threshold”; that CMS “provide physicians with more timely and actionable feedback in a more usable and clear format”; that CMS “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”; that CMS “simplify reporting burdens and improve chances of success by creating more opportunities for partial credit and fewer required measures within MIPS”; that the agency “reduce the thresholds for reporting on quality measures”; and that the agency “reward reporting of outcome or cross-cutting measures under a bonus point structure rather than a requirement in order to achieve the maximum quality score.”