7 comments on MACRA from industry-leading organizations

Monday's midnight closure of the comment period for the Medicare Access and CHIP Reauthorization Act — which determines how physicians will be paid under Medicare —was met with many comments and suggestions from across the healthcare industry.

Here are seven curated MACRA comments from industry leaders.

1. CMS should adjust the implementation timeline. The final rule is expected this fall, on or around November 1, and data collection will begin in 2017. In a letter to CMS, Donald Fisher, the president and CEO AMGA, a national organization representing medical groups and integrated delivery systems, suggested CMS delay the start of the 2017 performance year, perhaps to July 1, rather than January 1.  

2. MACRA needs to measure for value. AMGA's Mr. Fisher also called for CMS to measure outcomes in relation to spending under MACRA. "If value is left unaddressed in the final rule, it will be difficult at best for the agency to meet MACRA and the Secretary's overarching goals," Mr. Fisher said, referring to CMS' and HHS Secretary Sylvia Mathews Burwell's goals to tie an increasing percent of Medicare fee-for-service payments to value.

3. The scoring methodology and health IT measures should be more stringent to accelerate care transformation. The Consumer Partnership for eHealth, which represents consumer, patient and labor organizations, suggested CMS do away with the "one patient" threshold under Meaningful Use — which calls for a minimum of one patient to view, download or transmit their health information to a third party over a reporting period — that was broadened to apply to all measures under MACRA. This "undermine[s] CMS's commitment to make patients and family caregivers true and equal partners in improving health through shared information and shared decision-making. It sends the wrong signal — to the nation's patients and families, and to clinicians," CPeH wrote in its comment letter.

4. MACRA's Merit-Based Incentive Payment System must be aligned with hospitals' meaningful use programs. The American Hospital Association wrote to this specifically, requesting that CMS "offer a quality and resource use measure reporting option in which hospital-based physicians can use CMS hospital quality program measure performance in the MIPS," as well as "ensure alignment between the hospital meaningful use program and the ACI category of the MIPS."

5. MIPS also needs to be more streamlined. This is something the American Medical Association called for in its letter to CMS. To do this, AMA President James Madara, MD, wrote that CMS should "align the different components of MIPS so that it operates as a single program rather than four separate parts, such as creating a common definition for small practices," and that it should "simplify reporting burdens and improve chances of success by creating more opportunities for partial credit and fewer required measures within MIPS."

6. CMS should establish a pathway between MIPS and the Alternative Payment Model system, as well as expand what qualifies as an APM. The AMA suggested CMS simplify and lower financial risk standards for Advanced APMs, among other suggestions, to ease the transition between stages of MACRA.

7. The AMA called on CMS to provide an interim final regulation. The association felt the law had room for continued improvement and refinement. "By working together and maintaining an open dialogue, we believe we can make changes that allow physicians to achieve better care for their patients while reducing administrative burden and costs on practices," Dr. Madara wrote.


Editor's note: This article was updated June 29 at 8:55 a.m. CT to reflect that the comment period closed at midnight, not 5 p.m. We regret this error.


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