The AAFP partnered with four other physician organizations recently to rally support from CMS regarding patient-centered medicine homes (PCMHs) and their qualification as an alternative payment model (APM) under the Medicare Access and CHIP Reauthorization Act (MACRA).
In an April 22 letter(1 page PDF) to CMS Acting Administrator Andy Slavitt, AAFP President Wanda Filer, M.D., M.B.A., of York, Pa. -- along with her counterparts at the American College of Osteopathic Family Physicians, the American College of Osteopathic Internists, the American College of Physicians and the American Osteopathic Association -- pointed out that MACRA calls for "increased quality, efficiency and clinical practice metrics that existing models such as the PCMH support."
In fact, noted the organizations, the law highlights the PCMH model "as fully meeting the requirements of the clinical practice improvement activity category of the Merit-based Incentive Payment System (MIPS)."
The letter argued that PCMHs are "proven models" that have become increasingly popular in the past decade after the March 2007 release of a guiding document titled "Joint Principles of the PCMH"(3 page PDF) that was created by the AAFP and others.
The letter noted that MACRA outlines core criteria that must be present in an eligible APM; those criteria are
- quality measures comparable to those found in MIPS,
- certified electronic health record technology and
- the ability to bear more than nominal financial risk.
Or, an eligible APM could potentially be a medical home that meets criteria comparable to medical homes expanded as outlined by MACRA.
"All recognized or accredited PCMHs must demonstrate quality, take on practice improvement and make effective use of health information technology," noted the organizations. Furthermore, the law says medical homes need not demonstrate more than nominal financial risk.
"As such, we offer that recognized PCMHs should be included as eligible alternative payment entities under MACRA beginning in the program's first year," said the letter.
Evidence continues to show that this model improves patient care and lowers health care costs, pointed out the organizations. Furthermore, the PCMH is a model whose value has been proven -- as evidenced by its implementation in dozens of health plans, state Medicaid programs, multiple federal agencies "and thousands of clinical practices of varied sizes."
Therefore, the model should be "deemed as expanded" to meet the intent of MACRA and HHS' goal to move toward value-based payments," concluded the organizations.
It's important to note that the PCMH letter to Slavitt was sent before the proposed rule meant to guide implementation of MACRA was released on April 27.
The AAFP continues to review the proposal -- more than 900 pages in length -- to identify elements that directly affect family physicians and then craft recommendations to improve the regulation by CMS' June deadline.
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