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AMA Seeks Alignment of Meaningful Use, PQRS, VBM Objectives

By Kyle Murphy, PhD

The AMA wants CMS to align requirements for meaningful use, PQRS, and the VBM so that providers can avoid penalties.

The American Medical Association (AMA) is calling on the Centers for Medicare & Medicaid Services (CMS) to align the EHR Incentive Programs (i.e., meaningful use), Physician Quality Reporting System (PQRS), and the Value-Based Payment Modifier (VBM) in order that providers can avoid penalties.

“Physicians want to provide our patients with the best care possible, but today there are confusing, misaligned and burdensome regulatory programs that take away critical time physicians could be spending to provide high quality care for their patients,” AMA President Robert M. Wah said earlier this week.

In a letter to CMS Administrator Marilyn Tavenner, the association is also seeking the reversal of proposals to raise penalties for the programs by ten percent or more.

“These programs, with often incomprehensible, conflicting requirements and flawed implementation processes, are all entering their penalty phases and pose a risk to the stability of the Medicare program that many policymakers do not seem to appreciate,” writes AMA Executive Vice President & CEO James L. Madara, MD.

AMA claims that as a result of the separate legislative processes that created the programs policymakers have failed to recognize the “cumulative effect of a set of penalties that, when combined with a two percent payment sequester reduction, would total 11 percent in 2017 and grow to 13 percent by the end of the decade.”

Additionally, the association argues that the timing of these penalty programs pose a potential threat to the industry-wide effort to achieve ICD-10 compliance by Oct. 1, 2015.

“CMS is moving to implement these penalty programs at a time when physicians are scheduled to transition to ICD-10, which is a 68,000 diagnosis coding system — a five-fold increase from the current 13,000 diagnosis codes in use today,” Madara observes.

As the letter to CMS indicates, the federal agency finds itself in a difficult position as it attempts to meet the demands of the federal government. But that, writes Madara, should make CMS more sympathetic to the needs of healthcare organizations and providers:

It is hard to take the long view in an agency struggling to meet unrealistic deadlines with inadequate resources and a flawed IT platform. However, the current strategy of aggressively moving forward with policies that place an ever increasing burden on both CMS and physicians, combined with the flawed roll-out of the Medicare claims data release and Open Payments program and the problems with these programs, threatens to do serious damage to the agency’s image and to physician confidence in the government’s stated goal of achieving a health care system that delivers more value for the dollar. It is time to reassess where these programs are going and how to get there.

The AMA has offered a series of recommendations for improve each reporting program. Here’s a breakdown of those recommendations:

Meaningful use

  1. Remove the all-or-nothing provision; at the very least, make optional the measures that are the most challenging for the vast majority of physicians, including “View, Download, and Transmit,” “Transitions of Care,” and “Secure Messaging,” requirements which in many cases are completely outside the physician’s control.
  2. Require physicians to meet one set of quality reporting requirements (MU, PQRS, quality section of VBM).
  3. Shorten the 2015 reporting period to 90 days.


  1. Release the aggregate 2013 PQRS data.
  2. Create a formal appeals process.
  3. Maintain a robust set of claims-based measures and claims reporting option.
  4. Require physicians to meet only one set of quality reporting requirements (MU, PQRS, quality section of VBM).


  1. Penalties should not be increased.
  2. Participation in the budget neutral tiering process should be voluntary.
  3. CMS should ask Congress to provide a longer phase-in period and more flexibility to implement the VBM.

More information about the AMA’s position and recommendations are available here.




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