- The proposed rule for MACRA implementation requires eligible clinicians to begin their first performance year in 2017 which has drawn criticism from several leading industry groups.
In separate letters to the Centers for Medicare & Medicaid Services, the American Hospital Association (AHA), American Medical Association (AMA), Healthcare Information and Management Systems Society (HIMSS), Association of Medical Directors of Information Systems (AMDIS), and EHR Association to request have asked for additional time to prepare eligible clinicians to MACRA implementation.
Of its many recommendations to CMS, AMA first and foremost has advocated for a transitional period for eligible clinicians to ensure successful participation in the Quality Payment Program.
“The AMA strongly urges CMS to create an initial transitional performance period from July 1, 2017 to December 31, 2017 to ensure the successful and appropriate implementation of the MACRA programs,” wrote CEO James Madara, MD.
Additionally, the association seeks more flexible reporting periods. “In future years, for all required reporting requirements, CMS should allow physicians to select periods of less than a full calendar year to provide flexibility,” Madara continued.
The rationale behind the recommendation is the complexity of changes proposed by CMS.
We believe it is necessary for CMS to recognize the fundamental changes enacted as part of MACRA and treat the first year as a transitional period that allows physicians to move away from the existing Medicare reporting requirements, learn about MIPS and APMs, and implement workflow and system changes to become successful MACRA participants. We, therefore, believe that CMS should offer an alternative first MACRA performance period that begins July 1, 2017.
Likewise, AHA sees trouble ahead for hospitals given the timing of the final rule, expected to be publish as late as November 2016.
“Hospitals and their physician partners have many operational and strategic issues to consider in responding to the QPP, including quality measure reporting mechanisms, whether to pursue participation in advanced APMs, and necessary improvements to electronic health records, to name a few,” Executive Vice President Thomas Nickels argued.
To that end, AHA has called on CMS to closely monitor feedback from the field as to the readiness of providers to implement MACRA requirements and provide a flexible timeline for implementation. Additionally, the organization petitioned CMS to reduce the reporting period for the Merit-based Incentive Payment System for certified EHR users as part of the advancing care information performance category in 2017. AHA wants a 90-day reporting period instead of a full year.
A joint letter penned by HIMSS and AMDIS leadership has made the case for a 90-day reporting period in 2017 as a result of the various EHR- and health IT-related changes the healthcare industry would need to undertake to implement provisions of MACRA appropriately.
HIMSS and AMDIS included CMS technical readiness as a potential obstacle to overcome as well.
“While some preparations can be made in anticipation of the publication of the Final Rule, what must be done depends on what CMS finalizes, including changes that are made as a result of the feedback received from this NPRM,” it stated.
A reduced reporting period in 2017, they argued, would go a long way toward ensuring a successful MACRA implementation:
Over the long term, we understand the benefit of full-year reporting for all parts of the Quality Payment Program. However, given our concerns with this expedited timeline and changes that might need to be made for all non-quality related measures, we strongly recommend a 90-day reporting to allow an easier transition to this new program. We are hopeful that providers will report as soon as possible; requiring only a 90-day reporting period for ACI, CPIA, and in the APM Track would give a cushion if the technology and necessary workflow are not ready at the beginning of 2017.
EHR vendors are also concerned with the timing of MACRA implementation, according to the EHR Association. The trade association noted that health IT developers require sufficient time to prepare before even providers begin their performance periods.
“CMS should provide a minimum of 18 months’ notice for newly developed quality measures and benchmarks preceding the reporting period for which they are required,” the group stated. “The first 12 months will allow for vendor implementation, with the second six months providing for real-world beta testing of measures, as well as identifying and resolving defects and inconsistencies in a measure update for implementation the following year. We request a minimum of six months prior to any reporting period for implementation of revised measures.”
The general consensus from these and other letters to CMS on MACRA implementation is that the course proposed by the federal agency misses the mark on timing.