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AAMC submits comments on MACRA Quality Payment Program Final Rule

January 5, 2018

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PRESS CONTACTS
Kate Ogden, Physician Payment & Quality Specialist

The AAMC Jan. 2 submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Medicare Access & CHIP Reauthorization Act of 2015 (MACRA) Quality Payment Program (QPP) Final Rule. The AAMC is committed to working with CMS to ensure that MACRA promotes improvements in delivery of care, and is not overly burdensome to clinicians and the organizations for which they work. While the final rule includes improvements, the AAMC still has concerns with some of the components of the QPP provisions, specifically commenting on the following areas:

  • Risk Adjustment: Risk adjusting outcomes, population based measures, and cost measures for clinical complexity and sociodemographic (SDS) factors should be considered for all measures and utilized where appropriate.

  • MIPS Identifiers: In addition to using the TINs, NPIs, and APM identifiers, create an option for a MIPS identifier that would allow large multi-specialty groups to have sub-groups under the same TIN assessed in the quality payment programs in a way that is meaningful.

  • Cost Category: Maintain the cost category performance weight at zero and urge Congress to remove the mandate that the cost category be weighted at 30 percent in performance year 2019. Prior to implementation, address risk adjustment and attribution concerns related to the cost measures.

  • Improvement Activities: CMS should consider future expansion of new improvement activities related to teaching.

  • Extreme and Uncontrollable Circumstances Policy: Finalize the extreme and uncontrollable circumstances policy for 2017 and 2018 MIPS performance years and apply it uniformly under the QPP program so that group practices are also included.

  • Nominal Financial Risk Definition:Extend the revenue based nominal amount standard of 8 percent beyond 2020 to preserve stability in the program. Eliminate the 50 clinician cap on medical homes.

  • Other Payer Advanced APMs: Allow determinations of other payer advanced APMs to remain in effect for at least 3 years if there are no material changes in the A-APMs.

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