- Several healthcare advocacy organizations submitted comments on a recent proposed rule for the CMS Quality Payment Program (QPP), which implements MACRA, by Monday's deadline.
- The proposed rule in question exempts more small providers from the Merit-Based Incentive Payment System (MIPS), allows hospital-based physicians to report at a facility level, introduces virtual reporting groups and eases EHR requirements.
- Provider groups mostly praised the changes, but offered some tweaks and requests. One theme was desire for more advanced alternative payment models (APM) to qualify for MACRA.
Industry groups were generally pleased with the proposed rule, which aims to offer more flexibility for providers by delaying some requirements and easing burdens for smaller practices.
MACRA has broad support generally, but many providers worry they aren't prepared for the reporting requirements. A recent study by the American Medical Association (AMA) and KPMG found that fewer than one in four physicians feel well prepared to meet the requirements.
Providers also find fault with the time it takes to submit the quality measures. A Medical Group Management Association survey earlier this month found small practices view QPP as the most burdensome regulatory issue.
There is still concern, however, that delays and loosened requirements are a setback for value-based care models in general.
The American Medical Group Association (AMGA) said in its comments the CMS’ intention of increasing flexibility for providers creates an unneeded delay in the movement toward value-based care and “fails to recognize the significant investments made in preparation for participation” in MACRA. AMGA opposes the increase in the low-volume threshold for participation in MIPS and suggests keeping the current threshold.
The American Hospital Association (AHA), on the other hand, praised the threshold change and encouraged CMS to continue the increase for an additional year. It also called for a continuous 90-day reporting period for MIPS with the option to report up to a full year.
The AHA and the American Medical Association both support the proposal to allow physicians to select a facility-based measurement option, which AHA says will “help clinicians and hospitals better align quality improvement goals and processes across the care continuum and reduce data collection burden.” AHA does ask for future expansion to other facility types.
The AHA said it supports the proposal of bonus points awarded based on patient complexity, but encourages CMS to go further by incorporating sociodemographic adjustments as well.
Several groups called on the CMS to expand the definition of advanced APMs, and in particular to allow Medicare Advantage to qualify, noting its growing enrollment numbers.
The AHA also noted it remains disappointed that the criteria for an advanced payment model includes downside financial risk, which “fails to recognize the significant resources providers invest in the development of APMs.”