Slow it down or step on the gas?
When it comes to how fast the industry should jump into MACRA, there’s a difference of opinion among groups that represent physicians. In comments submitted Monday to the Centers for Medicare & Medicaid Services (CMS) in response to the final rule to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), three organizations took a stand on the timeline for implementation.
The Medical Group Management Association (MGMA) and the American Medical Association (AMA) urged CMS to give physicians flexibility in participating in MACRA beyond 2017—the initial year when the new Medicare payment system begins.
On the other hand, The American Medical Group Association (AMGA), a trade association whose goal is leading the transformation of healthcare in America, urged CMS to move ahead and fully implement what it is calling its Quality Payment Program (QPP) in 2018.
The final rule included a 60-day comment period that ended Monday. All three groups said they were pleased with the changes CMS made from its proposed rule to its final rule released in October, including its making 2017 a transition year and allowing a ‘pick your pace” option for clinicians participating under the Merit-based Incentive Payment System (MIPS)—a traditional Medicare program that most physicians will opt for under MACRA.
Only practices that do not participate at all in MIPS and do not send in any 2017 performance data will see their revenues drop with a negative 4 percent adjustment. All others will see payments remain steady or see an increase.
In a 10-page letter, the MGMA urged CMS to extend the initial one year transition period into 2018. "Rather than establish a cliff at the end of “pick your pace” on Dec. 31, 2017, CMS should gradually increase the MIPS participation requirements and performance thresholds and maintain the quality measure global floor minimum through at least the 2018 performance period," the MGMA said.
In its own 30-page letter, the AMA agreed, advocating for a longer transition period that, at a minimum, runs through 2018. While the 2017 transition year is helpful, “we believe a more realistic transition period will require additional time, and urge CMS to engage in a more measured ramp up to the full QPP requirements,” the AMA wrote.
The AMGA, however, stressed the importance of ensuring that the transition does not extend beyond 2017, “so that by 2018 providers who have made the significant investments in the health information technology, staff and cultural changes needed to succeed in a risk-based reimbursement system have the opportunity to do so,” the AMGA said in an announcement.
“We understand that not everyone is ready for risk,” said Donald W. Fisher, PhD, AMGA’s president and CEO. “And AMGA appreciates why CMS took the action it did. But moving forward, we hope that CMS continues to pursue its value agenda.”
The three organizations did agree on one point, however: They urged CMS to develop more advanced APMs so more practices can participate in that MACRA pathway.
All three groups joined with seven other organizations, including the American College of Physicians and the American Hospital Association, signing a letter to CMS urging the agency to move ahead with development of the Accountable Care Organization (ACO) Track 1+. That track incorporates less downside risk than what is required in existing two-sided ACO models, according to the organizations, that represent physicians, hospitals, medical group practices, academic medical centers and nearly all existing Medicare Shared Savings Program (MSSP) ACOs.
(This story was updated Dec. 21 to include the latest comments from the MGMA's Dec. 19 letter to CMS.)