The California Medical Association (CMA) submitted comprehensive comments to the Centers for Medicare and Medicaid Services (CMS) outlining constructive improvements for the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA).

“CMA is extremely concerned that the proposed rule does not go nearly far enough to fix the outlandish administrative burdens in the Medicare program as required by MACRA," CMA wrote in a letter to acting CMS administrator Andrew Slavitt . “In several instances, the MACRA merit-based incentive payment system (MIPS) rule is more complex than the existing programs. And the promising Alternative Payment Model (APM) track has been all but amputated.”

The MACRA law clearly mandated CMS to simplify and reduce the burdensome reporting programs as well as incentivize innovative new payment models led by physicians. CMA outlined the most serious areas of concern with the proposed rule, including:

CMA’s MACRA Technical Advisory Committee developed over 40 practical recommendations to simplify and improve the implementation of MACRA. In addressing the issue of participation for small practice and solo practice physicians, CMA suggested that the initial reporting period be moved back one year to January 1, 2018, and that CMS significantly expand the permanent MIPS low-volume exemption for small practice physicians and physicians located in health professional shortage areas.

CMA also suggested that there should be a phase-in pathway to help small and rural practices transition to MIPS, as well as safe harbors for small practices until virtual group reporting systems can be established. CMA also recommended that Medicare-Medicaid dual-eligible patients be excluded from the scoring system so physicians are not penalized for treating these complex patients.

In addressing the regulatory burdens of MIPS reporting programs, CMA recommended improvements to four reporting programs (quality, EHR advancing care information, resource use and the clinical improvement activities) that include reducing the scoring complexity of these programs. While CMS reduced nearly half of the quality measures, CMA is urging that more measures be eliminated, particularly the irrelevant EHR Meaningful Use Stage 3 measures, and that physicians should be given partial credit for any measures that are met, rather than an all-or-nothing approach. CMA also placed great emphasis on CMS holding EHR vendors more accountable for compliance and interoperability.

Finally, CMA urged CMS to provide more opportunities for physician-led payment models with reduced financial risk requirements and to extend the deadlines for physicians to participate in the Comprehensive Primary Care Medical Home models with private payors.

To read the CMA letter, click here.

Contact: Elizabeth McNeil, (800) 786-4262 or emcneil@cmadocs.org.