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Society submits comments on MACRA proposed rule

The Wisconsin Medical Society today submitted comments on the Medicare Access and CHIP Reauthorization Act (MACRA) proposed rule. MACRA replaces the Sustainable Growth Rate (SGR) formula and changes the way Medicare will pay physicians beginning in 2019, based off of 2017 reported data.

The Society was among many organized medicine stakeholders to support MACRA, in part because of anticipated consolidation and administrative simplification to the Medicare payment model in relation to current frameworks.

The MACRA proposed rule, which was released by the Centers for Medicare and Medicaid Services (CMS) in April, includes several improvements to current programs and lays out the foundation for the Merit-based Incentive Payment System (MIPS) program. Improvements include:

  • Eliminating overlapping quality measurement across separate programs.
  • Reducing measures overall and eliminating many thresholds.
  • More flexibility in measure choice.
  • Largely eliminating the pass/fail approach.
  • Significantly reducing financial risk from penalties.

 
CMS also incorporated a number of positive provisions in the Alternative Payment Model (APM) programs. They include:

  • Identifying a reasonable approach to quality measure requirements.
  • Adding an initial electronic health record (EHR) use proposal that allows for 50 percent of participants in the first year (although that threshold increases quickly).
  • Judging performance on group basis.
  • Establishing reasonable criteria for judging physician-focused payment models.

 
While the Society welcomes this progress, it believes many more improvements can be made and implementation of the proposed rule should be seen as a work in progress. Specifically, the Society is concerned that CMS did not make necessary changes to the Meaningful Use (MU) program, which is now called Advancing Care Information (ACI). It appears that the proposed rule primarily changes scoring without changing the actual measures. In its comments, the Society encouraged CMS to dramatically rethink its approach to the way it measures interoperability of EHRs, to provide needed greater flexibility, and to include regulations that focus on the goal versus the process.

The Society also expressed concerns regarding the short lead time for physicians to learn the rules and the inadequate time allotted to make practice adjustments. The Society specifically asked CMS to preserve a period of stability during MACRA implementation by providing for a period of transition and testing in the first three to six months of 2017. CMS should use that time period to conduct appropriate testing, including testing physicians’ ability to participate and validation and accuracy of scores or ratings, and to verify that CMS has the necessary resources to implement provisions regarding MIPS and APMs.

The final MACRA rule is expected to be released sometime in October. For more information, e-mail Chris Rasch, the Society’s director of state and federal relations.

Back to June 23, 2016 Medigram