Tuesday Sep 27, 2016
AAFP Advocacy on MACRA Implementation Paying Off
During the past year I have had the opportunity and privilege to listen to, and interact with, family physicians across the country -- including hundreds at the recent AAFP Congress of Delegates and Family Medicine Experience (FMX) meetings -- about the Medicare Access and CHIP Reauthorization Act (MACRA) and how it will impact their practices.
The responses from family physicians are (not surprisingly) mixed. Everyone I talked with was pleased that the sustainable growth rate (SGR) was repealed and the threat of substantial annual payment cuts were eliminated. Everyone was equally pleased with the emphasis and focus being placed on primary care as foundational to our national health care goals. Some see MACRA and the transition to value-based payments as an opportunity that will benefit primary care and patient care. Some, however, see the transition away from fee-for-service as a threat to their business model and their professional viability.
The majority sit between these two positions -- optimistic about the renewed emphasis on primary care focused delivery and payment models that support first contact, continuous, comprehensive and coordinated primary care. Scared about how it will work, what it really means for them, and how soon it will impact their practice. Regardless of whether you are optimistic, scared, or somewhere in between, the AAFP is committed to meeting you where you are and assisting you in your journey.
During my journeys and through my conversations with family physicians I have determined that there are three primary concerns:
- The new law is complex in design and hard to understand.
- Family physicians need flexibility in the early years to determine which of the two payment pathways is best for them and their practices.
- Family physicians, especially those in small practices, should be exempted from financial penalties that may result from their participation in MACRA, especially those penalties that are caused by methodologies that may be biased against them due to their small patient populations.
Earlier this year, the AAFP submitted a 107-page response to the proposed regulation implementing MACRA. I would encourage you to read the executive summary, which is much shorter and includes all the best information from the larger document.
In our letter, we accurately captured and articulated the three concerns mentioned above. Our letter raised significant concerns about the complexity of the proposed regulation, and we called on CMS to re-evaluate its approach to implementing the law. We also called on CMS to implement the law in stages so that all physicians, regardless of practice size and location, could have a positive experience with the new law in the initial years. We also urged CMS to identify a process whereby physicians could participate in the new quality payment program (QPP) in a manner that challenges their current capabilities but is within the realm of achievable for all family physicians in all practice settings. We requested that CMS identify and implement a primary care advanced alternative payment model for all primary care physicians, not just those fortunate enough to be in the CPC+ program. Finally, we suggested CMS create an opportunity for solo and small group family physicians to participate but be protected from financial penalties.
We have continued to press CMS on these items since submitting our letter and, I am pleased to report, CMS has been listening. On Sept. 8, the agency announced its intentions to provide physicians flexibility in the initial performance year of MACRA through a blog posting by CMS Acting Administrator Andy Slavitt(blog.cms.gov). In the post, CMS announced the "Pick Your Pace" program that would provide greater flexibility for physicians in the first performance year of MACRA, which is 2017.
I have been telling you how engaged the AAFP has been during the past 18 months on MACRA implementation and how we continue to pursue regulations that ensure that the law is implemented in a manner that is in the best interest of our members. Obviously, we have not and will not achieve every goal, but the Pick Your Pace announcement is a big one. The CMS announcement reflects the AAFP's recommendations, and we are pleased that CMS listened and acted based on our recommendations.
The Pick Your Pace approach provides four options for physicians:
- Option 1 -- Test the Quality Payment Program. If you submit some data to the Quality Payment Program, including data for services provided after Jan. 1, 2017, you will avoid a negative payment adjustment in 2019.
- Option 2 -- Participate for part of the calendar year. You may choose to submit Quality Payment Program information for a reduced number of days. This means your first performance period could begin later than Jan. 1, 2017, and your practice could still qualify, potentially, for a small positive payment adjustment. Like option 1, if you submit data, you avoid penalties in 2019.
- Option 3 -- Participate for the full calendar year. For practices that are ready to participate Jan. 1, 2017, you may choose to submit Quality Payment Program information for a full calendar year. This means your first performance period would begin on Jan. 1. Practices selecting this option would be eligible for full positive payment updates in 2019, but they also could face potential penalties depending upon performance.
- Option 4 -- Participate in an advanced alternative payment model (APM). Instead of reporting quality data and other information through the Merit-Based Incentive Payment System (MIPS), the law allows physicians to participate in the Quality Payment Program by joining an Advanced Alternative Payment Model (APM), such as the CPC+ program. If your practice receives enough of your Medicare payments or see enough of your Medicare patients through the Advanced Alternative Payment Model in 2017, then you would qualify for a 5 percent incentive payment in 2019.
The changes included in the Pick Your Pace program do not address all of our concerns, but they do create an opportunity for all physicians, regardless of practice size and location, to engage with the QPP program and avoid payment penalties in 2019. The AAFP continues to add resources and tools to our MACRA Ready campaign that can assist you in your journey towards the value-based delivery and payment programs.
Last week, the AAFP Congress of Delegates met in Orlando, Fla. The COD considered, debated, and approved numerous policies that will guide the policy and advocacy work of the AAFP. The hottest debate of the week focused on reducing the administrative burden facing family physicians, largely due to electronic medical records and prior authorization requirements. Delegates also had serious conversations about the escalating costs of prescription drugs, single-payer health systems and maintenance of certification. You can review the COD’s actions and read the resolutions debated at the AAFP Congress of Delegates site.
Looking for a little more information on the COD meeting? AAFP News is your best source of summaries and analysis of the work done by the COD.
Posted at 07:00AM Sep 27, 2016 by Shawn Martin