Testifying before the U.S. Committee on Finance, Centers for Medicare & Medicaid Services (CMS) Acting Administrator Andy Slavitt made known concerns about physician readiness for implementation of the new Medicare payment system. Physicians already know the answer to that problem—a later start date and transition period.
“We need to launch this program so that it begins on the right foot, and that means that every physician in the country needs to feel like they’re set up for success,” Slavitt said. “We remain open to multiple approaches. Some of the things … that we’re considering include alternative start dates, looking at whether shorter periods could be used and finding other ways for physicians to get experience with the program before the impact of it really hits them.”
CMS issued the Medicare Access and CHIP Reauthorization Act (MACRA) proposed rule earlier this year. The current start date for the new program is Jan. 1, 2017. In comments sent to CMS on the MACRA proposed rule, the AMA recommended starting the program on July 1, 2017, to provide additional time between the issuance of the MACRA final rule and the start of the reporting period.
The final rule is due in November, leaving physicians with just two months to prepare for and implement the most significant change to the Medicare payment system in more than two decades if the current implementation date stays in place. That’s clearly an inadequate amount of time for such major changes.
Why a later date and transition period would help
The proposed start date is too early and will create significant problems for the launch of the MACRA programs, the AMA said in its comments on the draft rule. CMS needs to recognize the fundamental changes enacted as part of MACRA and treat the first year as a transitional period that allows physicians to move away from the existing Medicare reporting requirements, learn about MIPS and alternative payment models (APM) and implement work flow and system changes to become successful MACRA participants.
The comments cite several reasons that physicians require a later start date and transitional period, including:
Time to prepare the tools
Setting the performance year too soon will compromise the ability for vendors, registries, electronic health record vendors (EHR) and others to update their systems to meet program requirements.
The MIPS program asks that these entities incorporate a significant number of new measures, and physicians have serious concerns that there will be inadequate time to not only include new measures but also to test and ensure the data submitted is accurate and reliable.
Starting too soon could worsen usability and add to the existing problems with technology.
Readying APMs
Physicians are also concerned that an early start date will limit the number of available APMs. A July 1 start date would provide time to modify CMS’ existing APMs so they can qualify under the MIPS or as Advanced APMs.
The Physician-Focused Payment Model Technical Advisory Committee (PTAC) is still in the process of developing the framework for reviewing APMs and has not had sufficient time to review or even recommend new models. A later start date gives the PTAC more time to conduct its work identifying physician-focused payment models.
More time to address physician concerns
Starting implementation at a later date would also provide more time for CMS to address several issues that were not in the proposed rule.
These unaddressed issues include the development of virtual groups, improved risk-adjustment and attribution methods, further refinement of episode-based resource measures and measurement tools, and more actionable feedback reports.
Physicians can’t report without the correct information
MACRA requires CMS to give timely feedback—such as quarterly reports—to physicians. By selecting Jan. 1 as the first performance period, physicians will not have received their first feedback reports. This would leave physicians without the information needed to successfully start the MIPS program, leaving them in the dark for over half of the first performance period.
MACRA also requires a quality development plan with annual progress reports, and the first report progress is supposed to be issued by May 1. By starting the program on Jan. 1, before the quality progress reports are finalized, CMS is skipping ahead and not finalizing key program requirements before it begins MIPS.
Learn more about the new Medicare payment system
- At the 2016 AMA Annual Meeting, Slavitt discussed how physicians are guiding the new payment system
- Learn about key changes the new Medicare payment system needs
- Find out how the new Medicare payment system intends to help small practices
- Take a walk through the 4 steps to prepare for MACRA implementation
- Learn the three principles driving the new Medicare payment system
