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AAFP Recommends CMS Simplify MACRA Implementation Requirements

AAFP recently issued recommendations to CMS for easing the strict MACRA implementation requirements.

MACRA Implementation

Source: Thinkstock

- The American Academy of Family Physicians (AAFP) recently submitted a letter to CMS suggesting ways the federal agency can simplify MACRA implementation requirements for providers.

Representing 124,900 physicians and medical students across the country, AAFP raised concerns regarding stringent MACRA requirements and the negative impact current policy could have on patient care.

 “While many industries face heavy regulatory burdens, it is difficult to imagine any industry that is more regulated than the practice of medicine,” AAFP Board Chair Wanda Filer, MD, MBA explained. “And to this point, there is not a single discipline of medicine that faces greater administrative and regulatory burden than family medicine and other primary care physicians.”

The organization cited a recent study in which physicians reported spending nearly half their workday on EHR documentation and administrative duties.

While MACRA was initially intended to serve as a welcome departure from unpopular and overbearing meaningful use requirements, AAFP contends the new changes may have done more harm to provider productivity than good.

AAFP members assert current MACRA implementation policy only adds to the complexity of Medicare payment, quality improvement, and performance measurement programs.

“This burden ranges from onerous documentation guidelines to cumbersome prior authorization criteria and the ongoing frustrations associated with electronic medical records,” Filer wrote.

AAFP offered CMS several recommendations on ways to simplify current requirements and improve MACRA implementation for both CMS and physicians: 

  • Remove the financial risk standards from regulatory definitions of Medical Home Model.
  • Remove arbitrary size restrictions limiting AAPM participation on Medical Home Models.
  • Eliminate all documentation guidelines for evaluation and management codes for primary care physicians in both the MIPS and AAPM pathways.
  • Jettison the complicated and entirely uncalled-for MIPS APM category.
  • Eliminate administrative claims population health measures.
  • Use consistent terms from proposed to final rulemaking to avoid confusion in the physician community

The alternative payment model (APM) category in particular has been the source of much controversy since its inception.

In March 2017, The American Hospital Association (AHA) similarly voiced dismay over the exorbitant burden APMs impose on providers. The financial demands of developing the infrastructure to enter into a new payment model outweighs the advantages of incentives presented by current MACRA policy. 

Doing away with this pathway of the Quality Payment Program could alleviate concerns over whether APM incentives are potentially more punishing than rewarding for participating providers.

“The implementation of MACRA will impact our health care system for years to come, and it must be done thoughtfully, carefully, and as simply as possible,” stated Filer. “The AAFP sees a strong and definite need for CMS to step back and reconsider the current approaches to MACRA, which we view as overly complex and burdensome to physicians.”

On top of suggesting CMS eliminate several provisions, AAFP also listed several modifications to existing requirements.

The organization listed potential policy improvements for areas including primary care payments, advanced APMs, and quality measures.

AAFP recommended using only core measure sets developed by the multi-stakeholder Core Quality Measures Collaborative and ensuring all physicians participating in MIPS meet identical program requirements to promote standardization and consistency in reporting. 

Additionally, AAFP suggested a more gradual MIPS transition period with more timely, clinically actionable feedback to ensure physician success with advanced APMs and to mitigate confusion.

“Given the significant complexity of these programs, we strongly encourage CMS to follow the AAFP’s recommendations by which CMS can better align the requirements with the goals and intent of the legislation,” Filer concluded. 

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