Since the enactment of the Medicare Access and CHIP Reauthorization Act, many organizations have worked with Congress and the Centers for Medicare and Medicaid Services to promote a smooth implementation of the two payment models. Although MACRA is an improvement over the flawed sustainable growth rate payment model, its implementation has been flawed. The Medical Association joined with many other groups continue to urge for further improvements to the program including calling on Congress to replace the 2020-2025 physician payment update freeze with positive payment adjustments for physicians, extending the Advanced APM bonus payments for an additional six years, and implementing several additional technical improvements to MACRA.
In a letter to Congress, more than 120 national and state medical organizations urged Congress to foster the continued success of MACRA by implementing positive payment adjustments for physicians to replace the payment freeze over the next six years, extending the Advanced APM bonus payments for an additional six years, and implementing several additional technical improvements to MACRA. The letter also outlined several additional technical changes for review:
- eliminating the requirement to set the MIPS performance threshold at the mean or median so CMS, rather than a pre-set formula, can determine whether physicians are ready to move to an increased threshold based on available data;
- allowing CMS to develop multiple performance thresholds, such as one for small and rural practices, to ensure a level playing field for all physicians;
- giving CMS authority to revise the participation thresholds needed to achieve Qualified Participant status for those participating in Advanced APMs;
- excluding Part B drug spending from calculations of APM financial risk, which would be analogous to technical corrections to MIPS made in the Bipartisan Budget Act of 2018;
- updating the Promoting Interoperability performance category to allow physicians to use certified electronic health record technology (CEHRT), health information technology that interacts with CEHRT, or a qualified clinical data registry (or a combination of all three technologies);
- prioritizing cost measures that are valid, reliable, and demonstrate variation by removing the requirement that episode-based cost measures account for half of all expenditures under Medicare Parts A and B;
- removing the total cost of care measure mandate as the existing measure is flawed and risks holding physicians accountable for costs that are outside their control, such as drug prices;
- allowing pay-for-reporting on new measures or when significant refinements to a measure or composite have been made (precedent already exists for introducing measures via pay-for-reporting in other value-based purchasing programs);
- providing authority for the Physician-focused Payment Model Technical Advisory Committee to provide technical assistance and data analyses to stakeholders who are developing proposals for its review; and
- aligning and improving the methodologies of MIPS and Physician Compare, as physicians currently receive two different scores and reports, which is confusing to physicians and patients and does not lead to quality improvement.