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AAMC Submits Comments to House and Senate Committees on SGR Repeal Proposal

November 14, 2013— AAMC President and CEO Darrell G. Kirch, M.D., submitted a Nov. 12 comment letter responding to the Senate Finance and House Ways and Means Committees’ bipartisan discussion draft Medicare physician payment reform proposal that would repeal the sustainable growth rate (SGR) formula, freeze Medicare physician payment through 2023, and move toward a payment system that rewards quality over quantity [see Washington Highlights, Oct. 31].

The letter highlights four AAMC recommendations, including changing the Value-Based Purchasing (VBP) Payment Program to reflect the current state of quality and cost reporting, requiring the Secretary of Health and Human Services to implement a group performance reporting option for the VBP Payment Program, requiring resource and outcome measures’ risk-adjustments account for socioeconomic status (SES) and demographic factors, and revising the alternative payment model (APM) implementation to increase physician participation.

In the letter, Dr. Kirch commends the committees’ “innovative concept” of consolidating the Physician Quality Reporting System (PQRS), Value-Based Modifier (VBM), and Electronic Health Record Meaningful Use (EHR MU) programs into the one VBP Payment Program, but also highlights the AAMC’s concern that the aggressive timeline could inhibit the program’s ability to “effectively and accurately capture performance” and may provide “poor measurement and unintended outcomes.”

The AAMC suggests the VBP payments be phased-in to allow for a transition period and limit risk until measures are more reliable.

Dr. Kirch suggests that a group reporting option be a legislative requirement, explaining this would encourage “care coordination and communication across the system.”  The letter points out a group reporting option would minimize the administrative burden of tracking individual physician performance, which can be a time-consuming and tedious challenge for physicians who work for multiple groups or are new to a practice.

The letter also urges the committees to “ensure the new legislation continues the requirement to have resource and outcome measures properly risk adjusted,” including taking into account socioeconomic status and demographic factors.  Dr. Kirch continues, “At a minimum the risk adjustment needs the protections that are currently in the Value Based Payment Modifier (VBPM).”

Regarding APM participation, the letter states the AAMC supports the concept but is concerned “about the feasibility of the current proposal.”  Specifically, the lack of existing APMs is a barrier to participation and the APM thresholds are not currently achievable.  To be most effective in achieving APM participation, the letter suggests a phased-in approach that would better “accommodate providers at all levels of APM readiness and implementations.”


Len Marquez
Director, Government Relations
Telephone: 202-862-6281

Courtney Summers
Senior Legislative Analyst
Telephone: 202-862-6042


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Jason Kleinman
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Telephone: 202-903-0806