AMA outlines what physicians need to implement MACRA, presses CMS for more time

Centers for Medicare and Medicaid Services

The American Medical Association has submitted comprehensive comments to the Centers for Medicare and Medicaid Services outlining changes that should be made to the proposed rule on Medicare payment and delivery reform, as created by the Medicare Access and CHIP Reauthorization Act.

The AMA's detailed recommendations seek to ensure that the new programs reward physicians for the improvements they make to their practice and the quality of care they provide to their patients. With what the organization called the "flawed" sustainable growth rate and its yearly, systemic threats of payment cuts now over, the AMA is urging changes across the programs, including specific revisions to the Merit-Based Incentive Payment System and the Alternative Payment Model option.

In its letter to CMS, the AMA outlines steps it thinks the agency should take to ensure a smooth transition to the new payment system -- so physicians have time to adopt and invest in their practices.

[Also: MACRA rules for physician payments stacked against small practices, critics say]

Among those steps is the creation of a transitional reporting period for the first year, ‪beginning July 1, to allow sufficient time to prepare physicians and enable a successful launch of the new Medicare payment and delivery system.

The AMA also recommends providing more flexibility for solo physicians and small group practices, such as modifying the low volume threshold, lowering reporting burdens, comparing practices to their peers and providing education, training and technical assistance to those practices.

Additionally, the organization suggests giving physicians timely and actionable feedback on their performance in a more usable and clear format.

The AMA also offered several recommendations on MIPS and APM. For MIPS, it suggests reducing what it deemed its "unnecessary complexity" by better aligning the different components so that the payment system operates as a single program, rather than four separate parts.

The AMA would also further simplify reporting burdens on physicians and create more opportunities for partial credit and fewer required measures; maintain the thresholds for reporting on quality measures at 50 percent to ensure that administrative burdens do not increase; and replace current cost of care measures that were developed for hospital-level measurement, which tend to have low statistical reliability when applied at the individual physician or group levels, and refine new episode of care measures prior to widespread adoption.

MIPS-wise, the AMA also recommends removing the pass-fail component of the Advancing Care information score and restructuring the EHR performance measures, rather than keeping the current meaningful use stage 3 requirements; and improving risk adjustment and attribution methods before moving forward with the resource use category, and reducing the number of required clinical practice improvement activities so reporting requirements do not become overly burdensome.

When it comes to APMs, the AMA's recommendations include simplifying and lowering financial risk standards for advanced APMs; basing the risk requirements on physicians' Medicare revenues instead of total Medicare expenditures so physicians do not have to take risks for expenses outside their control; and providing more opportunities for APM participation.

"Under MACRA, high-quality, high-value care and improved health outcomes for patients will be rewarded, but ensuring a smooth transition away from SGR requires up-front work today," said AMA President Andrew Gurman, M.D. "By working together with CMS and continuing an open dialogue, we believe we can make changes that allow physicians to achieve better care for their patients while reducing administrative burden or costs on practices."

The AMA isn't the only health organization recommending changes to CMS. HIMSS, for example, has asked CMS change the reporting period for the Advancing Care Information component of MIPS (which would essentially replace meaningful use for Medicare physicians) to 90 days. HIMSS wants CMS to "redouble its efforts" to ensure clinicians are better educated about MACRA requirements, and that the small practices are not too burdened with bureaucratic hoop-jumping.

With regard to the technology-focused Advancing Care Information requirements, HIMSS insisted that the "requirements are not overly burdensome" to eligible clinicians. CMS should ease the complexity of quality reporting," since "health IT reduces the need to retain claims and registry-based reporting."

The organization also requested CMS work more closely with the Office of the National Coordinator for Health IT to lessen "duplication and redundancies" related to surveillance and health information exchange, and that the agency help create more Medicare-focused Advanced APM options through, for instance, the Center for Medicare and Medicaid Innovation. It also asked CMS to broaden the role telehealth technology could play in helping meet requirements.

Twitter: @JELagasse