Today, ACP offered practical
solutions to physicians’ concerns about Medicare’s proposal to implement
the new payment system created by the Medicare Access and CHIP Reauthorization
Act (MACRA).
The College’s detailed recommendations, summarized here in a press statement that is linked to the comment letter
itself, would replace CMS’s proposed and unnecessarily complex quality scoring
system with a much simpler and understandable approach as developed by the
College. We challenge CMS to completely revamp how health information
technology is reported to make it less burdensome and more clinically relevant
to clinicians. We advocate that CMS
create safe harbors from payment reductions for smaller practices of 9 or fewer
clinicians until a “virtual reporting” system is established. We propose expanded choices and opportunities
for physician-led models to qualify for higher payments as “alternative
Advanced Payment Models”—including three new APM pathways for Patient-Centered
Medical Home Practices, including two that would not require physicians in such
practices to bear financial risk. And we
proposed many, many more ways that CMS can simplify implementation, ensure that
only reliable and clinical relevant quality measures are used, and create more
choices, more opportunities, and more flexibility for physicians in all
specialties and types of practices to be successful by recognizing their
ongoing commitment to improving care for their patients.
Among the detailed
suggestions that the letter offers to CMS:
- For the Merit-Based Incentive Payment System, the College proposed a distinctive alternative scoring methodology, developed by ACP, which combines, simplifies, aligns and reduces the complexity of the four reporting categories that will qualify physicians for FFS payment adjustments in 2019. The scoring approach included in the proposed rule had different points systems and scales for each of the four reporting categories, making it unnecessarily complicated; ACP’s alternative would put the points all on the same scale, combining them into one simplified and harmonized program as Congress intended.
- The
College proposed specific alternatives to CMS’s Advancing Care Information
program that is to replace the current Meaningful Use program.
The ACP alternative would make it easier for physicians to report
on and be successful in this category, in line with Administrator
Slavitt’s promise to revamp the program to simplify reporting and make it
more meaningful for clinicians.
- ACP
proposed additional improvements to simplify the reporting requirements
for the Quality, Advancing Care Information and Clinical Practice
Improvement categories. The College’s suggested changes to the
Resource Use category also included suggestions to reduce unintended
adverse impacts on physicians and their practices.
- ACP
urged CMS to immediately create virtual reporting options and to create
safe harbors for smaller practices until such options are available. The College recommended that practices
with 9 or fewer clinicians, should be held harmless from payment
reductions that would otherwise occur until the virtual reporting option
is available. ACP also suggested
that a virtual reporting option could be based on linking primary care
Patient-Centered Medical Homes with Patient-Centered Specialty Homes, a
concept long championed by ACP.
- The
letter also proposed more options and flexibility, instead of a one-size
fits all approach, for practices to be certified as Patient-Centered
Medical Homes or Patient-Centered Medical Home specialty practices,
qualifying them for the highest possible score for the Clinical Practice
Improvement Activity reporting category.
- The
College recommended that the initial reporting period for the quality
payment program be pushed back to July 1, 2017, rather than starting on
January 1 as CMS proposed. This would give physicians and their
practices the time needed to make the preparations required to be
successful.
- ACP
proposed four different options for Medical Home practices to qualify as
advanced Alternative Payment Models, instead of the single option proposed
by CMS, including options to allow PCMHs to qualify without taking
financial risk. These additional options would potentially
allow many thousands more practices to qualify and earn the 5 percent
bonus on FFS payments
- The letter suggested other changes that would make more advanced Alternative Payment Models available for physicians in all specialties, especially including those in internal medicine and its subspecialties.
The College’s approach of offering real solutions to real problems with CMS’s proposed rule will serve internists much better than ranting about MACRA—which regrettably characterizes much of the commentary about MACRA on social media. While physicians’ concerns about MACRA are understandable and must be addressed by CMS, I stand by my view, as expressed in a previous blog post, that MACRA’s overall framework is far better for physicians than the current flawed Medicare reporting programs—offering them opportunities to receive positive updates rather than just avoiding cuts, giving them credit for their own quality improvement activities, exposing them to less financial risk through 2021 than under the current penalties for not being able to successfully report, providing opportunities for thousands of practices that are Patient-Centered Medical Homes to qualify for higher payments. While I have had plenty of people express disagreement with that post, not a single one has been able to factually counter the specific improvements that MACRA makes over the status quo. They can’t—because they are baked into the law itself.
The question then is whether CMS’s proposed implementation
would accomplish the statute’s and Congress’s objectives to simplify and
harmonize quality reporting and to create opportunities for physician-led
delivery models to qualify for higher payments.
In ACP’s view, the proposed rule did have positive elements to move
payments in the desired direction, such as reducing the number of required
quality measures, but it fell far short in many other respects. Keep in mind that it is a proposed rule—the very reason it was out
for public comment was so that CMS could hear from doctors and others what it
got right and what it got wrong, and even more importantly, what alternatives
they would recommend to make it better.
Comments that just attacked the proposed rule, or the MACRA law itself,
will accomplish nothing: only Congress (not CMS) can amend MACRA, and CMS can’t
improve the proposed rule unless those offering comments can give them specific
ideas on what they should do differently.
Solutions, not rants, are what will bring about the needed changes.
That is what ACP did today, offer solutions that would, in
the words of Dr. Robert McLean, chair of ACP’s Medical Practice and Quality
Committee, "simplify the quality
reporting program, reduce the burden on physicians and especially smaller
practices, and propose more options and flexibility for physicians to qualify
for higher payments by recognizing their ongoing efforts to improve care to
their patients. With these improvements,
implementation of the new payment systems would go a long way to achieving
Congress’ goal of aligning payments with quality without imposing more
unnecessary administrative burden on physicians.”
Today’s question: What do you think of ACP’s recommendations
to CMS to simplify reporting and scoring, create safe harbors for smaller
practices, revamp the Meaningful Use program, and provide more opportunities
for physician-led Alternative Payment Models to qualify for higher payments?
2 comments :
http://medicaleconomics.modernmedicine.com/medical-economics/news/top-9-macra-threats-could-become-reality-doctors-patients?page=0%2C0
These are some of the likely reasons why physicians are skeptical
of MACRA despite Bob's and ACPs best salesmanly pitch.
It is what it is, and ACPs position is what it is. Each practitioner
simply needs to ask themselves whether ACP is representing
your interests or not.
What do veterans want?
H.E.Butler III M.D., F.A.C.S.,
Commander, USNR, Fleet Reserve
HButler@post.Harvard.edu
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