A 962-page proposed rule released Wednesday by the Centers for Medicare & Medicaid Services (CMS) details the draft regulations the agency is considering for implementation of last year’s groundbreaking Medicare reform law.
Goals for improving health care for patients and physicians
Ahead of CMS’ release of the rule, physician leaders testified to the U.S. House of Energy and Commerce Committee’s Subcommittee on Health during a special hearing last week on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
The physicians all underscored in their testimony the great potential the law holds for allowing physicians across the country in every specialty and practice setting to focus more on their patients and the innovations that are needed to improve quality, reduce costs and ensure the sustainability of their practices.
If implemented in a way that truly achieves these goals, MACRA could positively change the health care environment. “We think it may even bring back the joy of medical practice,” Robert Wergin, MD, board chair of the American Academy of Family Physicians, said in his written testimony.
Robert McClean, MD, of the American College of Physicians’ Board of Regents, expressed a similar hope for how the law will be carried out, noting in his testimony, “I truly believe that if MACRA can get rolled out with its best intentions implemented well, it is a remarkable ‘shot in the arm’ Congress can give to physicians and the rest of the clinician community to combat burnout and thereby enable our system to realistically strive for the Quadruple Aim.”
An AMA study conducted by RAND has shown that professional satisfaction for physicians is directly tied to being able to provide the highest quality care for their patients with the fewest administrative barriers to doing that. A second study by the two groups found that physicians recognize value in moving to new payment models but need support and guidance to be successful in them and assurance that new models will be sustainable.
Implementation of MACRA could address many of these issues. The intent of the law is to streamline the various Medicare reporting programs that have been so burdensome for physician practices, reward high-quality care, and provide opportunities and support for physicians to develop and adopt alternative payment models (APM).
“MACRA makes significant improvements over the current system, including the repeal of the flawed sustainable growth rate formula and giving CMS an opportunity to reset and improve performance measurement as well as other requirements,” Barbara McAneny, MD, AMA immediate-past board chair, said. “By increasing the availability of APMs, CMS will spur innovative delivery models focused on enhanced care coordination that can lead to better outcomes for patients.”
The proposed regulations
“While we have not yet digested the entire 962-page regulation, it appears on our initial review that CMS Acting Administrator Andy Slavitt and his senior management team have listened,” AMA President Steven J. Stack, MD, said in an AMA Viewpoints post.
Among other issues, the proposed rule addresses questions about elements of MIPS, including:
- Quality: In this category, clinicians would choose to report six measures, rather than the current requirement of nine measures, from among a range of options that accommodate differences among specialties and practice settings.
- Advancing care information: For this category, clinicians would choose to report customizable measures that reflect how they use technology in their day-to-day practice. Unlike the existing electronic health record (EHR) meaningful use program, this category would not require all-or-nothing EHR measurement or redundant quality reporting.
- Clinical practice improvement activities: This category would reward physicians for clinical practice improvements, such as activities focused on care coordination, patient engagement and patient safety. Clinicians would select activities that match their practices’ goals from a list of more than 90 options.
A work in progress
The AMA is eager to continue its work with CMS as the agency revises the regulations over the coming months.
“The 60-day comment period will provide physicians with an opportunity to offer constructive recommendations to share the final regulations that will be issued in the fall,” Dr. Stack said. “The AMA will continue its engagement with CMS during the comment period so that MACRA can live up to its promise.”
Since MACRA was passed last spring, the AMA has been providing extensive physician feedback on what should be included in the regulations under development. This has included numerous comment letters on specific aspects of MACRA implementation, as well as 10 overall principles the AMA and more than 100 other medical associations urged the agency to follow.
The AMA also has responded to CMS’ requests for information that provided advice on the agency’s proposal for a quality measure development plan and episode groups. Other activities have included hosting listening sessions with CMS for different medical specialties and other stakeholders.
To help physicians succeed under the new Medicare system, the AMA will be offering step-by-step guidance and practical resources for practices that will pursue participation in APMs or MIPS. Resources currently available include an expert-authored guide to physician-focused payment models, key points of MIPS and five things you can do now to prepare.
The AMA’s STEPS Forward™ collection of practice improvement strategies also offers a variety of education modules to help physicians take steps toward advancing team-based care, implementing electronic health records, improving care and practicing value-based care.
Additional resources and insights from practicing physicians and payment model experts will be available over the coming weeks and months.