In a July letter to legislators, the AAFP expressed continued support for "the goals and objectives established by" the Medicare Access and CHIP Reauthorization Act (MACRA) but raised concerns about the law's implementation.
"MACRA placed a priority on the transition of physician practices from the legacy fee-for-service payment model toward alternative payment models (APMs) that promote improved quality and efficiency," stated the AAFP's July 26 letter,(2 page PDF) which was signed by Board Chair John Meigs, M.D., of Centreville, Ala. "To date, the number of available APMs is not sufficient to achieve this goal."
The letter was sent to Reps. Michael Burgess, M.D., R-Texas, and Gene Green, D-Texas, the chair and ranking member of the House Energy and Commerce Committee's Subcommittee on Health,(energycommerce.house.gov) respectively, and was entered into the record for the subcommittee's July 26 hearing(energycommerce.house.gov) on MACRA's Merit-based Incentive Payment System (MIPS).
During the hearing, witnesses from five physician groups that had voiced concerns about MIPS were asked whether the program should be repealed; they advocated instead for program improvement driven by stakeholder collaboration.
The AAFP's letter took a similar stance, outlining areas the Academy recognizes as important to refine.
"Regarding MIPS," the AAFP wrote, "we are concerned with the continued complexity of the scoring methodology, lack of timely and clinically actionable feedback, and terminology changes."
The AAFP suggested the following improvements to the Quality Payment Program (QPP), the umbrella under which MACRA's MIPS and APMs fall:
- an opt-in pathway for MIPS-eligible clinicians who are below the low-volume threshold,
- retaining cross-cutting measures in specialty sets with fewer than six measures to ensure parity for all eligible clinicians,
- new ways to hold harmless physicians who cannot be reliably measured against at least one episode-based cost measure,
- decreased complexity of scoring in MIPS performance categories, and
- support for the Physician-Focused Payment Model Technical Advisory Committee's role in evaluating physician-focused payment models, as well as for broadening the definition of such models to include any public or private payment model.
The letter went on to note that, "While fee-for-service will always have a role, we are convinced that it is, in most instances, not congruent with the delivery of patient-centered, comprehensive and continuous advanced primary care."
The AAFP is carefully reviewing the proposed 2019 Medicare physician fee schedule, which for the first time also includes proposed changes to the QPP. Comments to CMS are due Sept. 10.
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