April 28, 2016
Area(s) of Interest: MACRA
The Centers for Medicare and Medicaid Services (CMS) on Wednesday released a 962-page proposed rule that lays out the agency's plan for implementing last year's groundbreaking Medicare payment reform law, the Medicare Access and CHIP Reauthorization Act (MACRA).
Ahead of CMS’ release of the rule, physician leaders testified before the U.S. House of Energy and Commerce Committee’s Subcommittee on Health during a special MACRA hearing last week. The physicians expressed cautious optimism and said the law represents a critical opportunity to enhance flexibility and innovation in health care that can lead to improved care and better outcomes for patients, but the law also needs to allow physicians to focus on patients by aligning and simplifying quality reporting and health information technology programs.
“MACRA makes significant improvements over the current system, including the repeal of the flawed sustainable growth rate formula and giving the Centers for Medicare and Medicaid Services an opportunity to reset and improve performance measurement as well as other requirements,” said Barbara McAneny, M.D., immediate past chair of the American Medical Association (AMA) Board of Trustees, who testified at the hearing. “By creating a single reporting program, the law gives us opportunity to streamline measures, reduce reporting burden and create flexibility.”
“By increasing the availability of physician-focused alternative payment models (APM), CMS will spur innovative delivery models focused on enhanced care coordination that can lead to better outcomes for patients," Dr. McAneny continued. "Importantly, the law acknowledges physician leadership is needed in developing APMs, which not only promotes participation but protects patients and can drive down costs.”
The proposed regulations
While there has not yet been time to digest and dissect the entire 962-page regulation, initial reviews indicate that CMS has listened to the input provided by the California Medical Association (CMA), AMA and others in organized medicine over the past year, with significant improvements in reducing the quality and meaningful use reporting burdens. Since MACRA was passed last spring, organized medicine has been providing extensive physician feedback on MACRA implementation.
Among other issues, the proposed rule sets forth elements of MACRA's Merit-Based Incentive Payment System (MIPS), including:
Quality: Physicians would choose six measures to report, rather than the current requirement of nine, from among a range of options that accommodate differences among specialties and practice settings.
Advancing care information: Physicians would be able to choose customizable measures that reflect how they use technology in their day-to-day practice. Unlike the existing meaningful use program, this category has reduced redundant reporting and would not require all-or-nothing electronic health record reporting success to receive credit.
Clinical practice improvement activities: Physicians would be rewarded for clinical practice improvements, such as activities focused on care coordination, patient engagement and patient safety. Clinicians would select activities that match their practices’ goals from a list of more than 90 options.
Cost: The existing value modifier has been revamped. This category would use 40 episode-specific measures to account for differences among specialties.
APMs: Advanced APMs would be exempt from the MIPS reporting rules and qualify for the 5 percent financial bonuses. These models include the new Comprehensive Primary Care Plus model and the Next Generation ACO models, as well as other APM models under which physicians accept both nominal risk and reward for providing coordinated, high-quality care. The new rule appears to provide some flexibility for physicians to switch between the fee-for-service MIPS program and APMs as they transition.
CMA and AMA will continue to work closely to provide feedback to secure additional improvements in the final regulations. CMA will be responding by the comment deadline through the AMA MACRA Task Force, composed of the national specialty and state medical associations, as well as a CMA member-comprised MACRA TAC, to advocate our position to CMS. We will also be working to jointly develop tools and educational materials to help physicians assess their options and prepare for the change.
To learn more about MACRA, visit AMA's resource center here.