American Medical Group Association, American Hospital Association, weigh in on Medicare’s proposed rule.
Today, August 21, 2017, is the final day to submit comments to the Centers for Medicare & Medicaid Services (CMS) on its 2018 proposed rule updating the requirements of the quality payment program for physicians and other eligible clinicians mandated by the Medicare Access and CHIP Reauthorization Act (MACRA).
Both the American Hospital Association (AHA) and American Medical Group Association (AMGA) have submitted their feedback in the form of a letter to CMS Administrator Seema Verma.
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Key recommendations from the groups address the following:
Low-volume threshold—Under the proposed rule, CMS would increase the low-volume threshold under the Merit-Based Incentive Payment System (MIPS) to $90,000 or less in Part B allowed charges, or 200 or fewer beneficiaries. As a result, CMS estimates that more than 900,000 otherwise eligible clinicians will be exempt from the program.
- AMGA: “In a well-intentioned effort to make the transition to value-based care as smooth as possible, CMS is delaying this transition,” said Ryan O’Connor, AMGA’s interim president and chief executive officer. “Excluding two-thirds of providers from the MIPS program does not meet Congress’ goal to transform Medicare into a value-based purchaser of care.”
- AHA: “The AHA agrees that CMS’s proposal to raise the threshold… would provide needed relief and additional time to transition into the MIPS for small and rural providers. However, to provide additional transitional flexibility, the AHA also urges CMS to retain a continuous 90-day reporting period for the quality category for CY 2018, while allowing groups to report up to a full year if they are ready to do so.”
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Medicare Advantage—This past May 31, AMGA along with nine other stakeholder groups including Premier, American Essential Hospitals, and the American Medical Association (AMA), forwarded a letter to the CMS Administrator arguing the agency has the regulatory authority to allow Medicare Advantage 10 (MA) providers to participate under the “Other” and “All Payer” Alternative Payment Model (APM) categories before performance year 2019.
- AMGA: AMGA encourages CMS to allow providers that have contracts with MA plans that meet the risk, quality, and certified electronic health information technology requirements to be considered for advanced APM status. AMGA recommends that CMS include MA beneficiaries in the beneficiary threshold test. This not only recognizes the risk providers take with MA contracts, but provides an other option for providers to participate as advanced APMs.
- AHA: The AHA supports the development of another payer advanced APM determination process and urges CMS to use it to mitigate provider burden where possible.
All-Payer Combination Option—CMS is proposing to make quality payment determinations under the All-Payer Combination Option at the individual eligible clinician (EC) level only.
- AMGA: “AMGA does not support the proposal. AMGA fails to understand the assumption that an EC participating under the Medicare Option ‘would likely have little, if any common group level participation in the Other Payer Advanced APM.’”
- AHA: “The AHA supports the development of an other payer advanced APM determination process and urges CMS to use it to mitigate provider burden where possible. The AHA also supports CMS’s proposal to allow APM entities to use the other payer advanced APM determination process when payment arrangements have not otherwise been reported by payer.”
Debra Shute is the Senior Physicians Editor for HealthLeaders Media.