CHICAGO — The American Medical Association (AMA) today submitted comprehensive comments to the Centers for Medicare & Medicaid Services (CMS) outlining changes that should be made to the proposed rule on Medicare payment and delivery reform, as created by the Medicare Access and CHIP Reauthorization Act (MACRA). The AMA's detailed recommendations seek to ensure that the new programs reward physicians for the improvements they make to their practice and the quality of care they provide to their patients. With the flawed sustainable growth rate (SGR) and its yearly, systemic threats of payment cuts now behind us, the AMA is urging changes across the programs, including specific revisions to the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) option.

In its letter to CMS, the AMA outlines critical steps the agency should take to ensure a smooth transition to the new payment system so physicians have time to adopt and invest in practices that result in improved patient care. These steps include:

• Creating a transitional reporting period for the first year, beginning July 1, to allow sufficient time to prepare physicians and enable a successful launch of the new Medicare payment and delivery system;
• Providing more flexibility for solo physicians and small group practices, such as modifying the low volume threshold, lowering reporting burdens, comparing practices to their peers, and providing education, training and technical assistance to these practices; and
• Giving physicians timely and actionable feedback on their performance in a more usable and clear format

"Throughout the years-long process of fighting to eliminate the deeply-flawed SGR, the AMA heard clearly from physicians that they want a new incentive system that reduces red tape, fosters flexibility and innovation in the delivery of care, and establishes a direct link between payments and quality of patient care," said AMA President Andrew W. Gurman, M.D. "While we believe CMS is expressing responsiveness to physician concerns in implementing the new law, we urge Acting Administrator Slavitt and his staff to make changes to the program rules to ensure physician and patient needs are met."

The AMA also offered several recommendations on MIPS and APM:

MIPS Recommendations:

• Reduce the unnecessary complexity of MIPS by better aligning the different components so that the payment system operates as a single program rather than four separate parts;
• Further simplify reporting burdens on physicians and create more opportunities for partial credit and fewer required measures;
• Maintain the thresholds for reporting on quality measures at 50 percent to ensure that administrative burdens do not increase;
• Replace current cost of care measures that were developed for hospital-level measurement, which tend to have low statistical reliability when applied at the individual physician or group levels, and refine new episode of care measures prior to widespread adoption;
• Remove the pass-fail component of the Advancing Care information (ACI) score and restructure the EHR performance measures, rather than keeping the current Meaningful Use (MU) Stage 3 requirements; and
• Improve risk adjustment and attribution methods before moving forward with the resource use category, and reduce the number of required Clinical Practice Improvement Activities (CPIAs) so reporting requirements do not become overly burdensome

APM recommendations;

• Simplify and lower financial risk standards for Advanced APMs;
• Base the risk requirements on physicians' Medicare revenues instead of total Medicare expenditures so physicians do not have to take risks for expenses outside their control; and
• Provide more opportunities for APM participation

"Under MACRA, high-quality, high-value care and improved health outcomes for patients will be rewarded, but ensuring a smooth transition away from SGR requires up-front work today," said Dr. Gurman. "By working together with CMS and continuing an open dialogue, we believe we can make changes that allow physicians to achieve better care for their patients while reducing administrative burden or costs on practices."

To assist physicians navigate the nuts and bolts of the new payment and delivery system, the AMA in April released online information and resources to help physicians navigate the changing landscape.