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Halamka on MACRA Final Rule: “CMS is Listening and I Thank Them”

October 20, 2016
by Rajiv Leventhal
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Health IT notable expert John Halamka, M.D., CIO of Beth Israel Deaconess Medical Center in Boston, recently weighed in on the Medicare Access and CHIP Reauthorization Act (MACRA) final rule on his blog, “Life as a Healthcare CIO.”

Halamka noted in his post that while the rule is still very complex, that is largely due to the Centers for Medicare & Medicaid Services (CMS) publishing stakeholder comments to the proposed rule and the agency’s response to those comments. “The good news is that CMS has been very responsive to feedback, creating a transition plan for adoption, reducing the number of criteria and extending the timeline which enables iterative learning before large scale implementation,” Halamka wrote.

Of note, when the MACRA proposed rule came out in April, Halamka took issue with the complexity of the rule, saying it took him 20 hours to read through it. He said at the time, “The 962 pages of MACRA are so overwhelmingly complex, that no mere human will be able to understand them.” He added, “As a practicing clinician for 30 years, I can honestly say that it’s time to leave the profession if we stay on the current trajectory.”

But this latest post took a far softer stance on the final rule, a lengthy 2,400 pages itself. He wrote, “In previous posts, I lamented the impact of the proposed rule on small practices, the linkage to the 2015 Certification Rule and the burden of measurement/reporting. Many organizations reported similar concerns.”

Halamka’s big takeaways from the final rule were: CMS created a transition year with an iterative learning and development period in the beginning of the program; adjusted the MIPS low-volume threshold ($30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients) exempting many small practices; established an advanced APM financial risk standard that promotes participation in robust, high-quality models (creating a Track 1+ ACO); simplified the  technology requirements and offered partial credit for progress on technology goals; and established medical home model standards that promote care coordination.

Halamka noted that in the past year he has spent time in the UK, Denmark, and China, watching how a single payer system and a more uniform, government administered approach works for society. He said it might take decades for the U.S. to evolve to a more uniform healthcare delivery system, as no shorter timeframe is possible in this country as healthcare stakeholders have diverse needs.

So, he concluded, “Think of the Quality Payment Program as the beginning of a journey. Some of it will work and some of it will not.  Some reimbursement choices will be expanded and others discontinued.   As long as clinicians are given flexibility along the way, and the overall burden is kept at a manageable level, I’m willing to pilot some of these programs and see how it goes. More to come as we get into the details of EHR certification (just the limited components we need for APMs), compute quality measures, and build analytic tools. CMS is listening and I thank them for it.”

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