- The Medical Group Management Association (MGMA) recently recommended MACRA implementation and other policy suggestions to the newly confirmed Secretary of Department of Health & Human Services.
In a letter to HHS Secretary Tom Price, MD, MGMA made suggestions regarding topics including administrative simplification, the Merit-based Incentive Payment System (MIPS), alternative payment models (APMs), EHR certification, and the Stark Physician Self-Referral Law.
In terms of simplifying the administrative process, MGMA suggests the HHS cut costs by improving HIPAA and engaging with leaders of medical groups in the healthcare industry to identify appropriate administrative standards to reduce costs in other ways.
To ease the transition to MIPS, MGMA suggests reducing the cost and reporting burden of the program through a 90-day reporting period, among other suggestions. A 90-day reporting period has been a frequent recommendation since the program’s inception.
“MIPS should not reward the quantity of reporting but the quality of care provided to patients,” the letter states.
Advance APMs, the other pathway for eligible clinicians to benefit from MACRA incentives, should be pushed as a way to save health organizations expenditure, according to MGMA, which also suggests HHS push the Physician-Focused Payment Models Technical Advisory Committee (PTAC) to accelerate the development of qualifying payment models for providers.
Additionally, HHS should work directly with the physician community when developing new models of care delivery and episode payments to speed the APM approval process.
“We also believe the goal of MACRA to support practices in transforming their care delivery models from fee-for-service to value-based is best accomplished by working directly with the physician community to design APMs,” reads the letter.
Finally, MGMA suggests the Office of the National Coordinator for Health Information Technology (ONC) delay requirements to move to the 2015 CEHRT requirements and provide greater flexibility in certification standards and simplify the Federal Physician Self-Referral Law.
“This regulatory environment,” the letter states, “has resulted in lost productivity and additional cost associated with the current certified EHR technology and the negative impact these systems can have on their interactions with patients.”
In addition to these baseline recommendations, MGMA attached a list of addenda to their letter to further streamline administrative processes for healthcare providers and organizations and ease the transition to MIPS.
Two of the suggestions the organization made in the interest of simplifying the administrative burden of healthcare involve adjusting prior authorization requirements. MGMA recommends curbing prior authorization abuses in health plans and implementing national standards to automate the process, as well as exploring the use of clinical decision support software as meeting prior authorization requirements.
Several other administrative-related suggestions seek for national standardization to ease electronic data interchange and the use of electronic acknowledgments. Standardization has been a primary concern in the healthcare industry since health organizations began seeking increased interoperability between providers.
To streamline and improve MIPS, MGMA suggests HHS continue using any 90-day consecutive reporting periods to collect EHR data on quality metrics and standardize reporting requirements across all MIPS categories by allowing reporting across categories to count toward performance instead of bonus points alone, among other suggestions.
MGMA recommends HHS improve delivery systems and provide a choice of payment models by revising the APM risk standard to account for the investment and operational risks inherent to moving from fee-for-service to risk-bearing arrangements.
The organization’s suggestions regarding reducing regulatory burdens on physician practices include establishing a hardship exception for all eligible professionals (EPs) subject to the 2018 Meaningful Use EHR Incentive Program negative payment adjustments as clinicians transition to MIPS, as well as standardizing the provider credentialing process across all payers.
Finally, MGMA seeks modifications to EHR certification and interoperability requirements in support of high-quality care delivery by delaying all requirements for providers to adopt 2015 CEHRT, and it calls for the development of a public-private initiative to augment and improve current HIT certification process in accordance with the 21 Century Cures Act requirements.