Industry Orgs Back 2018 MACRA Implementation Flexibilities

June 27, 2017 - Healthcare industry organizations largely applauded the recently-released 2018 MACRA implementation proposal from CMS. The medical organizations commended the federal agency’s continuation of the transition year into 2018 as well as the agency’s proposed efforts to facilitate small, independent practice participation.

In the 1,052-page proposed rule, CMS reiterated its commitment to support eligible clinicians, especially those in small and independent practices. The federal agency proposed several MACRA attestation flexibilities to back their commitment, particularly for the Merit-Based Incentive Payment System (MIPS).

If finalized, some notable MACRA attestation flexibilities in 2018 would include:

• More clinicians exempt from MIPS as the participation threshold would increase from 100 Medicare beneficiaries or $30,000 in Medicare Part B revenue to 200 beneficiaries and $90,000 in revenue

• Flexible MIPS reporting options through virtual groups, in which solo practitioners and groups of ten or fewer eligible clinicians partner to participate in MIPS

• Bonus MIPS points for eligible clinicians in small practices of 15 or fewer providers and for clinicians who treat medically complex patients

• Continuation of the “Pick Your Pace” MACRA attestation option in 2018

• Suspension of the MIPS cost performance category for another year

• Additional year of allowing the use of the 2014 edition of certified EHR technology

“We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient,” stated CMS Administrator Seema Verma. “That’s why we’re taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork.”

Industry organizations supported the additional MACRA implementation flexibilities. The American Medical Association (AMA) was one of these groups.

“In proposing these rules, the Administration has taken another step to make sure the promise of MACRA – where physicians are rewarded for improvement and for delivering high-quality, high-value care – will be fulfilled,” stated AMA President David O. Barbe, MD. “Patients and physicians will benefit from the new MACRA approach, as flexibility is vital when implementing a wide-ranging reform.”

MACRA implementation flexibilities should help clinicians who feel unprepared for the new value-based reimbursement program, including 64 percent of providers according to a February survey from Stoltenberg Consulting.

“This flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country,” Barbe added.

Other medical organizations praised CMS efforts to support small and independent practice participation via virtual groups.

“The new MACRA rule is a big win for small, independent practices,” Travis Broome, Healthcare Policy Lead at Aledade. Inc., said in an emailed statement. “The ‘preservation of independent clinical practices’ is now stated as a key aim of the Quality Payment Program, and the substance backs it up. Specifically, the new MACRA rule creates virtual groups that allow small practices to band together while keeping their independence.”

“Ultimately, it helps clear the way for smaller, independent primary care practices to maintain their independence and take the path into value-based care,” he continued.

Healthcare industry groups also tended to favor flexible EHR use requirements.

“[T]he proposal on EHR certification requirements for clinicians strikes a needed balance as the transition continues in 2018, by allowing MIPS eligible clinicians to continue to be able to use 2014 Edition certified EHR technology in 2018 but also offering bonus points in the advancing care information performance category for those clinicians that report using only 2015 Edition certified technology,” HIMSS announced on their website.

Building on comments from HIMSS, the American Hospital Association urged CMS to extend similar EHR use flexibilities to hospitals.

AHA Executive Vice President Tom Nickels also called on the federal agency to establish incentives for clinicians who collaborate with hospitals. “We also encourage CMS to provide additional opportunities for clinicians to earn incentives for partnering with hospitals to provide better quality, more efficient care through advanced alternative payment models,” he explained.

Despite general support for the proposed 2018 MACRA implementation flexibilities, the American Medical Group Association (AMGA) criticized the rule for failing to reward prepared providers.

“If CMS wants to transition to value-based payment for care, the program needs to be fully implemented,” said Chester A. Speed, JD, LLM, AMGA Vice President of Public Policy. “We recommend that CMS revise its proposal to fully incentivize high performers in the Medicare program.”

The industry group echoed its concerns from September 2016. AMGA leaders told CMS that the “Pick Your Pace” MACRA attestation rule would penalize prepared clinicians who have already made significant investments to meet MACRA requirements.

CMS invited healthcare stakeholders to submit comments on the proposed 2018 MACRA implementation rule by Aug. 21, 2017.