ACC Submits Comments to CMS on MACRA Implementation

The ACC submitted comments to the Centers for Medicare and Medicaid Services’ (CMS) Request for Information (RFI) on the implementation of the new payment system under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which replaces the flawed Sustainable Growth Rate payment system with two payment pathways. The Merit-Based Incentive Payment System (MIPS) incorporates elements of the current Medicare quality reporting programs – the Physician Quality Reporting System, the Meaningful Use program (MU), and the Value-Based Modifier – into a single program that will reward clinicians based on the delivery of high-quality, high-value care. The second pathway will provide incentives for clinicians who participate in eligible alternative payment models (APMs).

In its comments, the ACC urged CMS to ensure that the MIPS and APM pathways be based first and foremost on supporting the clinician’s ability to provide high-quality, evidence-based care to Medicare beneficiaries. In addition, the College stressed that the new payment system under MACRA must apply appropriate measures and requirements that recognize the diversity of clinicians and patient populations, and that CMS must continue to work with medical specialty societies and practices to ensure that program requirements are not administratively burdensome. Other recommendations from the ACC include:

  • Since Meaningful Use is a component of the MIPS score, CMS should reopen MU Stage 3 to realign the program to focus on interoperability and usability, and evaluate whether clinicians are successful under the Stage 2 Modifications rule. CMS must also eliminate the pass/fail approach to the program before integrating it into the MIPS program.
  • Quality measure reporting requirements should be based on clinicians reporting the most clinically meaningful measures based on their specialty and services provided. Arbitrary thresholds such as reporting a certain number of measures according to National Quality Strategy should be eliminated.
  • The collection of valid performance data is key to a pay-for-performance system. CMS should collaborate with Qualified Clinical Data Registry vendors such as the ACC and practices so that all stakeholders can better understand any data issues and work together to resolve them if they arise.
  • All resource use measures should be appropriately risk-adjusted so clinicians are not penalized for treating chronically ill patients. In addition, each resource use measure must be counter-balanced with an appropriate quality measure.
  • CMS should not mandate participation in any specific activity under the new Clinical Practice Improvement component of the MIPS program. Clinicians should be permitted to participate in those activities that meaningfully drive improvements in care based on their patient population, specialty and practice size.
  • CMS must provide clinicians with usable, accessible and actionable feedback reports that truly allow them to assess their performance and identify areas of improvement.
  • CMS and the Centers for Medicare and Medicaid Innovation should work with the private payer community to align quality measures, allowing clinicians to easily transition between the MIPS program and APM participation.

CMS will use the comments collected through the RFI to develop proposed regulations that are expected for release around March 2016. To learn more about MACRA and ACC’s approach to preparing members for the upcoming changes, read a recent Journal of the American College of Cardiology Leadership Page from ACC President Kim Allan Williams Sr., MD, FACC; Paul N. Casale, MD, MPH, FACC, a member of the ACC Board of Trustees; and William J. Oetgen, MD, MBA, FACC, executive vice president of Science, Education and Quality for the ACC. Issue briefs on MACRA, MIPS and APMs are available on

Keywords: Centers for Medicare and Medicaid Services (U.S.), Chronic Disease, Mandatory Reporting, Meaningful Use, Medicaid, Medicare, Registries, Reimbursement, Incentive, Medicare Access and CHIP Reauthorization Act of 2015

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