AAFP Sends Recommendations on Implementing New Payment System to CMS

Wednesday, April 20, 2016

Leslie Champlin
Senior Public Relations Strategist
American Academy of Family Physicians
(800) 274-2237, Ext. 6252

LEAWOOD, Kan. — The American Academy of Family Physicians has called for implementation guidance on regulations that--by focusing payment on accurate measures and minimizing administrative burden for primary care physicians--would help expand patients’ access to comprehensive, coordinated and efficient health care for decades to come.

The AAFP’s call came during testimony presented by AAFP Board Chair Robert Wergin, MD, during a House Energy and Commerce Subcommittee on Health hearing on the Medicare Access and CHIP Reauthorization Act. The Centers for Medicare & Medicaid Services is expected to issue regulations implementing MACRA, which repealed the sustainable growth rate formula and replaces it with Medicare payment systems that focus on value-based payment.

“The AAFP has launched a comprehensive, multi-year, member education and communications effort designed to simplify the transition and provide the guidance members need to realize the benefits of MACRA and value-based payment, both for their patients and their practices,” Wergin told the subcommittee. Moreover, he added, “Last week, we advised CMS of our concerns with how the agency might handle many features of the new law.”

The AAFP’s recommendations call on CMS to:

  • Address the flaws in the existing fee-for-service payment system that undervalue primary care, since the fee-for-service payment will remain part of most new payment models, including the Merit-Based Incentive Payment System.
  • Ensure the existence of an Alternative Payment Model, established in MACRA, for primary care physicians.
  • Use the Core Measure set developed by the Core Quality Measures Collaborative.
  • Re-examine the structure and documentation guidelines required for evaluation and management services.
  • Avoid the real potential for overly complex regulatory implementation.
  • Define the patient-centered medical home without requiring third-party recognition.
  • Grant greater flexibility in the initial MACRA performance year, because it is unrealistic to begin measuring performance on January 1, 2017, since regulations will not be finalized until late this year.
  • Adopt a 90-day reporting period for meaningful use in 2016.
  • Attribute patients prospectively to the physician practice, so patients can engage with the medical team and physicians will know for whom they are responsible for quality reporting.

Wegin’s testimony follows an April 11 letter he sent to Andy Slavitt, acting CMS administrator. The letter was prepared in advance of the meeting and therefore did not reflect any new policies included in the CPC+ proposal announced by CMS on April 11.

“The AAFP believes that MACRA is, by intent and design, a law aimed at transforming our health care delivery system into one that is based on a strong foundation of primary care,” Wergin wrote in the letter. “A review of the law clearly demonstrates that Congress wanted a greater priority placed on comprehensive, continuous, coordinated, first contact, and connected primary care. The emphasis placed on these priorities and the significant attention paid to the patient-centered medical home, in particular, are direct articulations of Congress’ desire to see our health care delivery system more aggressively promote, reward, and emphasize primary care as the foundation of our health care system.”

Taken together, the recommendations will help ensure successful implementation of MACRA, Wergin wrote in the letter.

“We recognize that a robust and well-financed health care system built on primary care is a goal that CMS also strongly supports, and we look forward to working closely with you to ensure that MACRA facilitates the achievement of that goal,” he wrote.




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Founded in 1947, the American Academy of Family Physicians represents 134,600 physicians and medical students nationwide, and it is the only medical society devoted solely to primary care.

Family physicians conduct approximately one in five of the total medical office visits in the United States per year – more than any other specialty. Family physicians provide comprehensive, evidence-based, and cost-effective care dedicated to improving the health of patients, families and communities. Family medicine’s cornerstone is an ongoing and personal patient-physician relationship where the family physician serves as the hub of each patient’s integrated care team. More Americans depend on family physicians than on any other medical specialty.

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