- Earlier this week the Department of Health and Human Services announced a notice of proposed rulemaking for MACRA implementation that would end meaningful use, realign clinical quality reporting, and transform how Medicare physicians are paid through value-based reimbursement. As the dust settles on the new proposed rule, more industry groups have shared their views on the future of value-based care.
The American Medical Group Association (AMGA) released a statement that commended CMS for created the Advancing Care Information program, which provides flexibility for EHR and quality reporting, but it is concerned that the value-based reimbursement programs are limited.
Under MACRA, healthcare providers are able to join either the Merit-Based Incentive Payment System (MIPS) or an Advanced Alternative Payment Model (APM). Medicare physicians will also be able to switch between the two payment systems.
“We understand the rulemaking process is part of an ongoing conversation with CMS,” said Donald W. Fisher, PhD, CAE, AMGA’s President and Chief Executive Officer. “Based on a very preliminary look, CMS appears to have recognized the need for flexibility as providers move toward a risk-based payment system. However, we remain concerned that qualifying as an APM remains challenging at best, even for AMGA members, many of whom are very experienced with risk-based payment models.”
AMGA also voiced disappointment with MACRA’s timeline for quality assessments.
Medicare Part B providers, such as physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists, will begin to report through MIPS starting in January 2017. AMGA questioned if clinicians in MIPS will have enough time to comprehend the new program that will be finalized in the fall of 2016 and start by the new year.
The industry group also made several other comments about the proposed law, including:
• Healthcare provider quality performance will be evaluated at the group level, which acknowledges the care coordination that most AMGA members provide.
• The Advancing Care Information, which replaces meaningful use, is flexible and recognizes that the all-or-nothing approach to meaningful use and quality reporting was challenging for healthcare providers.
• AMGA is concerned that Track 1 Accountable Care Organizations (ACOs) are not included in Advanced Alternative Payment Models. Many AGMA members have invested their resources into creating care delivery infrastructures and organizational change that support Medicare Shared Savings Program, including Track 1 ACOs.
In addition to AGMA, the American College of Rheumatology (ACR) has voiced its views on the new value-based reimbursement structures. ACR shared its support for the proposed rule and its flexibility with quality and EHR reporting.
It also expressed support for the new payment systems, which provide Medicare physicians with payment options that encourage value-based care.
“The Centers for Medicare & Medicaid Services (CMS) has issued its highly anticipated proposed rule on the Medicare Access & CHIP Reauthorization Act (MACRA),” explained Joan Von Feldt, MD, MSed, ACR President in an official press release. “MACRA replaces the sustainable growth rate (SGR) formula and represents a significant shift in how rheumatologists are reimbursed for the Medicare services they provide. Initial review of the proposed rule suggests that CMS has been listening to the rheumatology community’s concerns about developing a value-based payment system that works to assist, and not hinder, the ability of rheumatologists to deliver high-quality care to Medicare patients living with rheumatic diseases.”
ACR also acknowledged that the new value-based payment programs are simple and convenient for smaller healthcare providers, like rural rheumatology providers. By reducing clinical quality measures, redefining MIPS and APMs, and supporting the use of clinical data registries, the proposed rule will help rheumatology providers to provide quality care.
“The importance of rheumatology care to our nation’s Medicare program cannot be overstated. Rheumatic diseases are the nation’s leading cause of disability and cost the U.S. healthcare system an estimated $128 billion annually,” continued Von Feldt. “Given the growing demand for rheumatology care and the shortage of rheumatology specialists available to provide care to Medicare patients, it is imperative that the new payment system and reporting requirements be simple, transparent, and tenable – especially for small and rural rheumatology providers.”
“We are therefore encouraged to see that CMS has included provisions in the proposed rule that reduce quality reporting burdens, offer clarity on how to qualify for an Alternative Payment Model (APM), define the components of Merit-Based Incentive Programs (MIPs), encourage the use of Qualified Clinical Data Registries (QCDRs) such as the American College of Rheumatology’s (ACR) RISE registry, and provide some flexibility in terms of outcome measures.”
The proposed rule would fundamentally change how healthcare providers are paid under Medicare payment programs. With the transition to value-based care, providers are looking to MACRA for guidance on how to implement quality improvements and certified EHR technology to get paid for their services.
The statements on the rulemaking from HHS are still fresh and some healthcare industry groups are still digesting the upcoming changes.