Ten provider associations have added their voices to the call for the government to modify regulations to count Medicare Advantage to qualify under the Medicare Access and CHIP Reauthorization Act (MACRA) as early as 2019.
The associations, which represent physicians, hospitals, multispecialty medical group practices, academic medical centers and nearly all accountable care organizations, provided the Centers for Medicare & Medicaid Services with a regulatory pathway that would allow providers to have their Medicare Advantage (MA) contracts considered as part of the threshold requirements to qualify as advanced Alternative Payment Models (APMs) under MACRA.
The groups sent a joint letter (PDF) on May 31 to CMS Administrator Seema Verma, making their case for a change that would allow qualifying Medicare Advantage contracts to be used to meet the minimum requirements for MACRA’s 5% advanced APM bonus.
Earlier in May, 10 organizations representing both physicians and payers asked HHS Secretary Tom Price to expand the options under MACRA for physicians and physician groups to include advanced APMs that are part of Medicare Advantage plans.
Among the groups writing the letter to Verma was AMGA. “Congress provided a framework with MACRA to move toward a system that is based on value,” said Chester A. Speed, AMGA’s vice president of public policy, in an announcement. “This proposal builds on that effort and illustrates the opportunity that CMS has to increase APM participation by recognizing how participating in qualified Medicare Advantage plans can help providers meet the challenging advanced APM eligibility requirements.”
Under the final rule released last October to implement the new physician payment system under MACRA, CMS determined that the program will include traditional fee-for-service Medicare revenue and patients but did not allow Medicare Advantage plans to qualify as an advanced APM until the 2021 payment adjustment year.
In the letter, the groups proposed a workaround that would change that restriction. While the MACRA statute does not support the inclusion of revenue associated with an MA contract as part of the revenue thresholds test in 2019 and 2020, the law does not prevent CMS from considering MA enrollees under the number of beneficiaries test, the groups said.
The National Association of ACOs (NAACOS), which also signed the letter, said the change makes sense. “It’s essential to recognize the work ACOs are doing with MA plans to propel the shift to value-based care and alternative payment models. It makes little sense to wait to count MA Advanced APM participation when those efforts reinforce the goals of MACRA,” said NAACOS President and CEO Clif Gaus.
Along with AMGA and NAACOS, the organizations signing the letter to Verma included Premier healthcare alliance, American College of Surgeons, American Medical Association, American Osteopathic Association, America’s Essential Hospitals, Healthcare Leadership Council, Healthcare Transformation Task Force and the Medical Group Management Association.