The American College of Rheumatology (ACR) continues to provide feedback to the Centers for Medicare & Medicaid Services (CMS) about the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 on behalf of rheumatologists. The bipartisan bill repealed the Sustainable Growth Rate and transitioned Medicare from fee for service to a system that bases reimbursement on the quality of care delivered, called the Quality Payment Program (QPP).
ACR Joins AMA on QPP Recommendations
The AMA sent a letter earlier this year, on which the ACR was a signer, requesting policies the CMS should work toward to make the transition to the QPP more successful. The comments focused on these three areas:
- Establish a more gradual transition period;
- Promote successful participation; and
- Simplify Merit-based Incentive Payment System (MIPS) scoring.
A more gradual transition period has been voiced by many provider organizations. The AMA letter states, “CMS has limited this flexibility to 2017 without providing guidance for what will occur in future program years. CMS should take advantage of this flexibility and adopt a similar transition year for 2018 to allow physicians to become more familiar with the program and keep program requirements stable.” A transition year that extends into 2018 would give more time to providers to make sure their office is capable of a full transition switch. The CMS is requiring the use of some electronic health record (EHR) technology that has not been produced yet. The AMA letter states, “By 2018, physicians will be required to purchase a new EHR version despite the fact that most of these products are still under development and benefits of the new technology are not yet realized.”
To promote more successful participation during the transition year, the AMA has requested that, “CMS can set the MIPS performance score threshold to promote successful participation by ensuring a greater number of physicians are held harmless from penalties.” Meaning that the standard by which CMS will judge providers’ quality of care should be lower in the early years, in addition to the implementation of substantially lower penalties for attempting to comply with the program.
Simplifying the MIPS scoring schema is another comment that has received universal support within the provider community. The old PQRS program requirement for quality measures was defined by a 9:3:2 ratio: nine measures across three domains with two outcome/cross-cutting measures. MIPS has simplified this quality measure requirement to contain any six applicable measures with at least one outcome or high-priority measure. But even with this reduction, the six-measure requirement remains high for most practicing specialists. The AMA letter commented to the CMS, “With six required quality measures, the category remains too high and administratively burdensome.”