- The American Medical Association is the lead subscriber of a recent letter to CMS Administrator Seema Verma calling for changes to the EHR quality reporting programs MACRA implementation is set to replace as well as reduced EHR documentation requirements for physicians following the passing of the 21st Century Cures Act.
“As indicated in the MACRA law and final regulations, policymakers in Congress and the Administration clearly understand that fair and accurate measurement of physicians’ performance will not be possible until better tools become available,” the letter states. “We are extremely appreciative of the efforts CMS has made to recognize and compensate for methodological shortcomings in MU, PQRS, and VM.”
Joining AMA are scores of state medical associations and medical academies in a call for CMS to take additional steps to address challenges related to the EHR Incentive Programs (i.e., meaningful use or MU), Physician Quality Reporting System (PQRS), and Value Modifier (VM).
“Consequently, we urge the Administration to take a series of steps to address these same challenges in MU, PQRS, and VM prior to their replacement by MACRA and minimize the penalties assessed for physicians who tried to participate in these programs,” the physician organizations advise. “Clearly this would send a strong message to the physician community about the extensive regulations with which physicians have been dealing and the Administration’s commitment to reduce the burden.”
In addition, the subscribers to the letter refer to a provision of the 21st Century Cures Act that charges CMS with establishing a strategy to reduce the EHR documentation burden on providers:
To fulfill this legislative directive, we urge CMS to establish a new “Administrative Burden” category of hardship exemption for the 2016 MU performance year. Eligible providers should not be penalized for focusing on providing quality patient care rather than the arbitrary “check the box” requirements of MU. Creating an administrative burden hardship exemption would provide immediate relief for those impacted by the programs that predate MACRA.
Also, the physician organizations seek the creation of a hardship exemption that would allow physician attempting but failing to successfully report PQRS data in 2016 as a result of complex and numerous reporting requirements avoid a two-percent Medicare penalty in 2018.
“The AMA has heard from many physicians who tried to successfully report PQRS 2016, but were unable to find nine measures that were applicable and meaningful for their specialty. Physicians also reported difficulties with the requirements that one measure had to be a cross-cutting measure, and the nine measures had to cover three National Quality Strategy Domains,” the letter reads.
The subscribing organizations highlight the federal agency’s decision to reduce reporting requirements during the first year of the Quality Payment Program as an acknowledgment on the part of CMS that providers are likely to find the reporting requirements difficult.
Along similar lines, the letter includes a recommendation that CMS help physicians avoid the four-percent penalty tied to VM reporting.
“As a starting point, any physician who avoided the PQRS penalty in 2018 should be exempt from any VM penalties as well,” it reads. “These physicians would then all be eligible to participate in a voluntary quality-tiering program where positive, negative, or neutral payment adjustments would be distributed based on a comparison of performance on the applicable VM cost and quality measures for all tiering-eligible physicians, including those who chose not to enter the tiering process.”
The letter was sent more than a week after the Senate voted to confirm Verma as the next head of CMS, following Acting Administrator Andy Slavitt and former Administrator Marilyn Tavenner in leading up the federal agency.