Wisconsin Medical Society staff met with Andy Slavitt, acting administrator of the Centers for Medicare and Medicaid Services (CMS), on Tuesday in Washington, D.C., as part of the Society’s involvement in the American Medical Association’s (AMA) Medicare Access and CHIP Reauthorization Act (MACRA) implementation task force.
Administrator Slavitt described to the group ways in which CMS has listened to the physician community and made recommendations in the proposed MACRA final rule designed to ease reporting burdens and provide more flexibility. He acknowledged, though, that the proposed rule—which sets the stage for MACRA implementation—still needs significant work, and CMS is seeking frontline feedback regarding unintended consequences the proposed rule might cause. Comments on the proposed rule are due June 27.
Society CEO Rick Abrams and Director of State and Federal Relations Chris Rasch represented the Society and on Wednesday participated in a daylong meeting to help the AMA and organized medicine formulate a response to the proposed rule. (The Society also plans to submit comments.) The task force did a thorough dive into the 962-page document, including a section-by-section review of the Merit-Based Incentive Payment System (MIPS) quality reporting, resource use, advancing care information, and clinical practice improvement components, as well as the specific proposals included in the Alternative Payment Models (APMs).
There is a strong emphasis on the usage of Quality Clinical Data Registries (QCDRs) throughout the rule. In fact, CMS stated the following:
“To encourage the use of QCDRs, we have created opportunities for QCDRs to report new and innovative quality measures…Finally, we allow for QCDRs to report data on all MIPS performance categories that require data submission and hope this will become a viable option for MIPS eligible clinicians. We believe these flexible options will allow MIPS-eligible clinicians to more easily meet the submission criteria for MIPS, which in turn will positively affect their composite performance score.”
It was clear to the group that QCDRs will play an increasingly important role as MACRA implementation progresses. Many national specialty societies have or are developing their own QCDRs, and because Wisconsin has one of the few multispecialty QCDRs in the nation that works, Wisconsin physicians who utilize the QDCR are well positioned.
However, one issue of concern with the proposed rule is the lack of a test period and the short time period between when the final measures and structure are made public, and when physicians have to start submitting measures on Jan. 1, 2017.
To help physicians prepare for MACRA implementation and to assist them in making the shift to value-based care, the AMA has several resources available on its MACRA Web page. Included in the materials are “5 Things You Can Do to Prepare” as well the Steps Forward Transformation Series, which has and will continue to develop modules to help physicians implement MACRA and value-based care.
The Society is one of just five state medical societies that are members of the MACRA implementation task force and looks forward to further participation in this and other important national committees. For more information, contact Chris Rasch.
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