The pending implementation of the Medicare Access and CHIP Reauthorization Act (MACRA) is a big deal in the medical world because once all the puzzle pieces are in place, Medicare payment to physicians will be handled very differently.
So it's not surprising that medical organizations are banding together to ensure the details that shape the law will benefit their members.
Such was the case recently when the AAFP joined 40 other organizations -- including the AMA, the American Osteopathic Association and the American College of Physicians -- to present CMS with four specific recommendations regarding alternative payment models (APMs) and the Merit-based Incentive Payment System (MIPS).
In an April 18 letter(3 page PDF) to CMS Acting Administrator Andy Slavitt, the organizations made their intentions clear up front:
"Our collective goal is to ensure the implementation of MACRA does not create an overly prescriptive, time-consuming and complex federal approval process for clinical quality improvement and APMs as this could undermine existing programs that are already extraordinarily effective in improving care and containing costs," they wrote.
Even though each organization holds unique perspectives and concerns regarding the law's rollout, there was unanimous agreement on four "overarching topics."
The organizations first asked that as CMS develops policy to implement MACRA it not disrupt the positive effects already occurring in beneficiaries' health thanks to models like the patient-centered medical home and accountable care organizations.
Both are considered APMs and they have shown "great promise and proven potential" in the battle to improve health care quality and reduce costs.
They called on CMS to allow "maximum flexibility" to help private and public sector APMs work together without encountering conflicting requirements.
Furthermore, CMS must avoid creating rules for participation that dampen the ability of physicians and payers to innovate.
"Ensuring a broad variety of APMs that suit local markets and the diversity of physician practice -- including both primary care and other specialties -- is essential to achieving the goals of this program," the organizations wrote.
The coalition also called for CMS to create a "clear pathway" for private sector models to qualify for APMs. The letter noted the "significant amount of success" in the development of private sector APMs involving health plans, employers and physicians.
"We fear that this work risks coming undone by creating stringent rules on APMs that make it impractical or untenable for clinicians to participate in both private sector and Medicare APMs," they added.
In addition, the organizations called on CMS to ensure that its definition of "virtual groups" relative to MIPS will allow small independent physician practices to remain viable.
"The opportunity for physicians to form virtual groups and build organized systems of care is an essential piece that can help sustain their ability to remain independent while mitigating further consolidation under MACRA," they wrote.
Lastly, the organizations told CMS that physicians should have "ample opportunity" to receive credit for existing clinical quality improvement activities if they choose to participate in the MIPS track.
"These successful collaborations between physicians and health plans can serve as a first step for physicians who are not able to be part of a larger APM, but who do want to be part of a value-based care model."
The groups reminded Slavitt that the Office of Management and Budget is reviewing the proposed rule and that the MIPS rollout begins in less than one year.
"Maximum flexibility and timely, clear guidance is imperative to ensure a smooth transition for all stakeholders," they wrote.
The group called on CMS to work with them to build "meaningful solutions to this complex yet transformative law."
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