- CMS received 3,849 comments on the MACRA implementation proposed rule.
- The proposed rule was released in May.
- Early reactions to the rule criticized the proposed rule could adversely affect small practices.
The comments varied on takes and requests. Some seemed to be useful feedback, such as "I am writing to request that CMS explicitly recognize continuing medical education (CME) activities provided by a nationally-recognized accreditor as a clinical practice improvement activity within the Merit-Based Incentive Payment System (MIPS)." Another commentator thought "too much payment emphasis is being placed on EHRs." Other comments seemed to offer no improvement suggestions, such as one commentator stating, "This is a disaster. Please stop making the practice of medicine impossible."
In its letter to CMS, the AMA outlined 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 included:
- 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.
The organization also want to delay reporting requirements back six months to July 1, 2017.
Aledade's letter to CMS called for some changes to the regulation, including, "Allowing independent practices to come together in “virtual groups” now for all aspects of MIPS reporting, and rewarding their clinical practice and health IT advances as they work towards participation in APMs (like gain share only ACOs) and on to AAPMs." In addition, the letter calls for greater administrative flexibility for small businesses by comparing performance under MIPS to similarly-sized peers.
HIMSS urged CMS to expand the role of both telehealth technology and program requirements in the final rule. Also the organization noted, "With the short timeline from the release of the final rule to January 1, 2017 (the intended start of the first reporting period), HIMSS recommends that CMS change the reporting period for the Advancing Care Information Performance Category of MIPS to 90 days."
- MIPS should be more simplified;
- Telemedicine needs to be a bigger player in the program;
- The MIPS reporting start date is too aggressive; and
- The new Advancing Care Information -- what will phase out Meaningful Use -- needs a 90-day reporting period if only for the first year.