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AAMC Comments on CY 2016 PFS Proposed Rule

September 11, 2015

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PRESS CONTACTS
Ivy Baer, Senior Director and Regulatory Counsel

The AAMC Sept. 8 submitted a comment letter on the Centers for Medicare and Medicaid Services’ (CMS) Physician Fee Schedule (PFS) proposed rule for calendar year (CY) 2016. The AAMC appreciates that CMS has chosen to propose minimal changes for the upcoming year as the move towards the new physician payment system established by the Medicare Access and Children’s Health Insurance Program (CHIP) Reauthorization Act of 2015 (MACRA, P.L. 114-10) will be sufficiently challenging in subsequent rulemaking.

AAMC’s comments focus on the following: feedback on MACRA implementation, quality reporting programs, Physician Compare Website, payment for care coordination, and potential changes to physician self-referral regulations.

In response to a CMS request for ideas regarding the implementation of MACRA, the AAMC commented on two important issues. The association strongly encourages CMS to create a group reporting option for the Merit-Based Incentive Payment System (MIPS) to ensure a smooth transition for academic practices that have already adopted this reporting option. The AAMC also recommends that CMS ensure that its alternative payment model (APM) implementation policies are broad and reflect the numerous contracting arrangements that exist between physician practices and other partners in the health system.

Additionally, the proposed rule outlines the final rules and requirements for the Value Modifier (VM) program and Physician Quality Reporting System (PQRS) payment adjustments. Given that both programs will transition to MIPS starting in 2019, CMS continues many of the policies from 2015. The AAMC is concerned that the VM scoring methodology does not properly account for those providers who care for complex patients and urges CMS to incorporate appropriate risk-adjustment in the methodology.

As a part of the agency’s broader efforts to improve transparency, CMS proposes the Achievable Benchmark of Care (ABC) methodology for the Physician Compare Website. The AAMC believes that before this methodology is finalized, CMS should conduct more thorough analyses to ensure that it addresses factors such as risk adjustments, variation in reporting mechanisms and programs, and patient complexities. The letter also states that CMS should not develop a single 5-star rating system for physicians, as it is impossible to distill the variety of healthcare services offered into a valid and comparable single composite score.

Finally, the AAMC commends CMS for proposing advanced care planning codes. The proposal provides payment for the time that physicians now spend with patients and their families and/or caregivers, conversations that are essential to providing patient-centered care.

The final rule will be released later this year.

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