AMGA releases initial statement on proposed MACRA rule

April 29, 2016

AMGA released an initial statement on the Centers for Medicare and Medicaid Services (CMS) proposed rule for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and acknowledged the efforts CMS has dedicated toward implementing the new payment structures required by the law.

“We understand the rulemaking process is part of an ongoing conversation with CMS,” said Donald W. Fisher, Ph.D., CAE, AMGA’s president and chief executive officer. “Based on a very preliminary look, CMS appears to have recognized the need for flexibility as providers move toward a risk-based payment system.  However, we remain concerned that qualifying as an APM remains challenging at best, even for AMGA members, many of whom are very experienced with risk-based payment models.  We look forward to analyzing this rule and engaging with the agency to refine this proposal before it is finalized.”

The rule implements two payment systems: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs).   The rule also proposes to allow clinicians to switch between MIPs and the Advanced APM track.

MIPS applies to Medicare Part B clinicians, including physicians, physician assistants, nurse practitioners, clinical nurse specialists, and certified registered nurse anesthetists. All Medicare Part B clinicians will report through MIPS beginning in January 2017.  AMGA remains concerned about the quick timeline, as Medicare will begin assessing performance under a new program that will be finalized in the Fall of 2016 and effective in less than six months.

Additional AMGA initial observations include:

  • Provider performance will be assessed at the group level, which recognizes the type of integrated care that AMGA members provide.
  • The rule proposes a MIPS performance category called “Advancing Care Information,” which would replace the Meaningful Use program.  This appears to be customizable and acknowledges the flaws with the current “one-size-fits–all” electronic health record (EHR) measurement and reporting program.
  • The rule also details the criteria for Advanced APM participation.  AMGA is disappointed, however, that Track 1 ACOs are excluded from Advanced APMs.  AMGA member medical groups have invested significant financial, clinical, operational, and leadership resources to establish the sophisticated care management infrastructures and organizational cultures necessary to support the goals of Medicare Shared Savings Program, including Track 1 ACOs.

To help members better understand the program and better prepare themselves for risk-based payment models, AMGA has launched a MACRA and Risk Initiative.  As part of this effort, AMGA will offer a number of educational materials, webinars, and opportunities for members to learn more about the law and its impact on medical groups, health systems, and other organized systems of care, including integrated delivery systems.

AMGA staff is closely reviewing the proposed rule and will provide detailed comments in the near future.