ACC Submits Comments to CMS on Proposed MACRA Structure

On June 27, ACC Advocacy submitted extensive comments [PDF] to the Centers for Medicare and Medicaid Services (CMS) on the proposed regulations to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) based on the feedback of key member groups, including ACC’s Health Affairs Committee, Partners in Quality Subcommittee, MACRA Task Force, NCDR Management Board, the Health Information Technology (Health IT) and Informatics Task Force, and several member sections and workgroups.

The MACRA legislation repealed the flawed Sustainable Growth Rate (SGR) formula, which focused on fee-for-service payment, where higher performing physicians had no ability to earn more for outcomes. Replacing SGR with MACRA will pave the way for a new payment system that places importance on quality care. MACRA also creates stability for Medicare payments by mapping out payment updates for ten years and beyond – stability that was severely lacking under the SGR formula. These regulations will establish rules for clinician participation in both the Merit-Based Incentive Payment System (MIPS) and qualifying for incentive payments based on participation in Advanced Alternative Payment Models (APMs) beginning with the 2019 payment year.

In the comments to CMS, the ACC noted the complexity of implementing a new payment model like MACRA and agreed that simplified education and assistance from CMS will be needed to ensure that members are prepared for implementation. The ACC encouraged CMS to revise policies to allow clinicians reporting data as a group to report and be scored on the most relevant measures to their clinical practice. The College recommended that clinicians be “held harmless” from penalties if it becomes apparent that clinicians are having trouble transitioning to the new policies.

Other key comments from the ACC include:

  • Refining the “low volume” MIPS exemption threshold to make it more available to cardiologists, particularly those in small practices and those treating a primarily pediatric or non-Medicare population.
  • Refining the “non-patient facing” clinician definition to ensure that the flexibility offered under this category is available to cardiologists, particularly imaging specialists. The ACC also advocated that quality improvement initiatives performed as part of laboratory accreditation be recognized as clinical practice improvement activities under MIPS.
  • Recommending how CMS should provide clinicians with clear and actionable feedback to ensure that they understand their reporting requirements and whether or not they are successfully meeting criteria.
  • Recommending that CMS increase flexibility for the Advancing Care Information component of MIPS (formerly Medicare Electronic Health Record [EHR] Incentive Program, also referred to as Meaningful Use) to provide opportunities for success, including a delay in requiring the 2015 Edition EHR certification.
  • Strongly opposing the proposal to substantially increase the successful reporting threshold from 50 percent to 80 percent or 90 percent of all applicable patients, despite ACC’s support of the collection of all-payer data to improve the sample size for quality reporting.
  • Recommending a cautious approach to the implementation of new episode groups for measuring clinician cost and resource use. The ACC warned CMS of the complexity of measuring clinician cost performance, especially when treating patients with chronic conditions.
  • Supporting a process in which clinicians and groups can request that CMS review their MIPS data if they believe that the Agency has assigned an incorrect score or penalty.
  • Supporting CMS’ recognition of the role of registries in quality improvement, including proposals to have Qualified Clinical Data Registries such as NCDR’s PINNACLE Registry and the Diabetes Collaborative Registry accepted as a MIPS reporting mechanism and clinical practice improvement activity.
  • Highlighting the need to make participation in APMs recognized under the MIPS APM and Advanced APM pathways more available to cardiologists, including recommendations to consider models such as the Bundled Payments for Care Improvement (BPCI) program as a MIPS or Advanced APM.

CMS will release the final regulations by Nov. 1, 2016, which will go into effect on Jan. 1, 2017 – the proposed start of the reporting period under the new payment program. The ACC will continue to work with CMS throughout the regulatory process to establish details of how the law will function. The ACC will also be developing education and resources to help members prepare for the changes ahead. Stay tuned to ACC.org/MACRA for the latest information and resources.

Keywords: Centers for Medicare and Medicaid Services (U.S.), Certification, Diabetes Mellitus, Electronic Health Records, Fee-for-Service Plans, Mandatory Reporting, Meaningful Use, Medicaid, Medicare, Quality Improvement, Registries


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