The AAMC June 27 submitted a comment letter in response to the Centers for Medicare and Medicaid Services’ (CMS) proposed rule on the Medicare Access CHIP Reauthorization Act (MACRA) physician payment system.
The new payment system, also referred to as the Quality Payment Program (QPP), involves two payment options for physicians: the Merit-based Incentive Payment System (MIPS) and the Alterative Payment Models (APMs). CMS would begin to measure performance for physicians and other clinicians through MIPs in calendar year (CY) 2017 with payment adjustments based on their performance beginning in CY 2019. The AAMC encourages CMS to make the QPP more flexible to allow for successful participation. Additionally, the letter states that QPP should not disadvantage physicians within the academic medical community who are caring for the most complex and vulnerable patients and, therefore, risk adjustment must be incorporated when appropriate.
While the AAMC appreciates that CMS has made efforts to reduce burden and complexity, the association remains concerned about a number of provisions in the proposed rule. The AAMC recommends simplifying the proposed MIPS program, increasing opportunities for physicians to transition to new delivery payment models, and accommodating the needs of physicians in large multi-specialty practices.
Within the MIPS payment track, CMS will assess eligible clinicians on four performance categories: quality, resource use, clinical practice improvement activities (CPIA), and advancing care information (ACI). The AAMC is pleased that CMS has proposed to continue group reporting options, and added group reporting under the ACI performance category. However, the AAMC recommends that CMS needs to establish an additional identifier to assess clinicians in large multi-specialty groups that may have clinicians participating in multiple different payment tracks.
Additionally, some other key recommendations for CMS to consider include: requiring eligible clinicians on less measures (e.g. reporting on four measures rather than six) and giving full credit for CPIA to eligible clinicians participating in APMs, similar to those participating in Patient Centered Medical Home (PCMH) models.
In the proposed rule, CMS has further defined a series of requirements to qualify as Advanced APMs. Clinicians who qualify as Advanced APM participants will receive a five percent bonus and do not need to meet the requirements under MIPS. The AAMC encourages CMS to expand the list of Advanced APMS to include the Bundling Payment for Care Improvement (BPCI) initiative and Comprehensive Care for Joint Replacement (CJR) model, and other models. While some of these are facility-led models, it is important to acknowledge that physicians are central to the success of these models. Additionally, the AAMC notes that CMS needs to revise the definition of nominal financial risk to take into account the financial risk of redesigning practices when participating in Advanced APMs.
The AAMC recommends that CMS establish a fast-track approval system for additional APMs known as Physician Focused Payment Models. The five percent bonus pool is only available for five years and, therefore, other clinicians should have more timely opportunities to participate in models and qualify for the bonus payment.
The AAMC June 21 joined the American Medical Association in a letter to CMS regarding the MACRA proposed rule that reinforced the above recommendations. The final rule is expected to be released in November 2016.