While various healthcare association groups are pushing for a delay to the start of the Medicare Access and CHIP Reauthorization Act (MACRA)—currently scheduled to begin on Jan. 1, 2017—one association representing physician organizations is urging the feds to stay on track.
In a letter written to U.S. Department of Health & Human Services (HHS) Secretary Sylvia Mathews Burwell, CAPG, a group representing 250 physician organizations, is calling on federal officials to implement MACRA as proposed in the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Schedule and Criteria for Physician-Focused Payment Models Proposed Rule, by Jan. 1, 2017, the program’s scheduled start date.
According to the letter, CAPG members already participate in pay-for-performance initiatives, alternative payment models and advanced alternative payment models. “Our members have successfully operated under risk-based payment models with commercial and Medicare Advantage payers for over two decades. In addition, our members currently participate in the full spectrum of CMS delivery system reform initiatives, ranging from bundled payments to the Next Generation ACO program,” the letter reads.
CAPG says that any delay to MACRA will disadvantage those physicians and physician organizations that have been preparing for implementation of this law for over a year. Physicians and physician groups have responded to MACRA in various ways including assessing quality measures and implementing systems to report for MIPS; applying for and participating in advanced APM models; and hiring additional staff to ensure the validity of quality data submissions, the group attests.
MACRA implementation is supposed to begin in 2017 with bonuses being paid out to eligible Medicare doctors in 2019. But, as comments from healthcare stakeholders poured in since the release of the proposed rule in April, many physician groups have called for a host of greater flexibilities, many which center around pushing the start date back.
What’s more, in the past year, many healthcare professional associations have stated outright that they are not well-prepared for the new law. Up until the release of the proposed rule in April, there seemed to be little awareness about the health IT provisions of MACRA amongst the provider community. Nonetheless, CAPG says that many of the nation’s physicians are indeed ready for MIPS or APMs—the two new Medicare payment program options.
“Their readiness stems from a few facts,” the letter states. “First, the predecessor programs that predominantly comprise the MIPS track have been in existence for many years, including: the Physician Quality Reporting System (PQRS) since its enactment in 2006; the value modifier program since its enactment in 2010; and meaningful use since its enactment in 2009. MACRA aims to consolidate and streamline these programs which have been in place for years.”
In the letter, CAPG also notes that MACRA represents a reduction in the potential penalties for physicians and physician groups as compared to current law and regulation—even for small and solo practices. However, nearly all discussion of late has been how under the current conditions of MACRA, small and solo practitioners could soon be seeing the end of their independence.
The letter concludes, “We are highly concerned about the implications of delay in a Presidential election year. As you know, January will bring a new Congress and a new Administration charged with the oversight and implementation of MACRA. We fear that any initial delay of any duration may open to the door to additional delays as the new Congress and Administration work through the complexities of the legal and regulatory regime. The best course of action is to adhere to the proposed implementation schedule and to make tweaks and adjustments to the law and regulations as it unfolds in practice.”