- The healthcare provider community has shown some concern about MACRA implementation and the quality payment program. The Advisory Board released a survey last month showing that 70 percent of 30 medical groups were concerned about MACRA regulations and the quality payment program. The Medical Group Management Association sent a letter to CMS Acting Administrator Andrew M. Slavitt on December 19 offering recommendations for improving the MACRA quality payment program.
To alleviate provider concerns regarding MACRA regulations, the recommendations from the Medical Group Management Association include decreasing regulatory burdens among physician practices by improving the “harmonization between the four MIPS categories,” keeping the flexibility of MIPS [Merit-Based Incentive Payment System] reporting after 2017, and decreasing the quality reporting periods to any consecutive 90-day time frame.
Other recommendations involve allowing the advanced Alternative Payment Model (APM) and MIPS participating providers to use 2014 or 2015 certified EHR technology until 2020 as well as release important MIPS information like quality measure benchmarks and quality improvement guidance.
“CMS should mirror its own policy for non-patient facing eligible clinicians (ECs) and scale the low-volume threshold to the group practice level, exempting a group from MIPS if 75 percent or more of its ECs individually fall below the low-volume threshold or the group’s average Medicare allowed charges and Medicare patient population falls below the threshold,” the Medical Group Management Association provided another recommendation in their letter.
The American Medical Group Association (AMGA) also sent a letter to the Centers for Medicare & Medicaid Services (CMS) last month outlining how the federal agency could improve the advanced APM and MIPS quality payment programs. In particular, the AMGA recommends changes to the proposed ACO Track 1+.
The AMGA urges the design of ACO Track 1+ to include availability for all ACO participants, the ability for ACO demo and ACO program participants to take part in this track during any performance year, and to incorporate regional financial benchmarking. Additionally, the letter calls for bigger incentives or higher shared savings in this particular track than in ACO Track 1 as well as beneficiary attestation.
“AMGA supports these recommendations primarily because the MSSP and the Medicare Advantage programs need to be on a level playing field,” Donald W. Fisher, Ph.D., President and CEO of AMGA, stated in the letter.
“As MedPAC argued in chapters one through three in its June 2014 report to Congress, ‘a major issue is that Medicare’s payment rules and quality improvement incentives are different and inconsistent across the three payment models,’ or across FFS, MA and MSSP. We note particularly the disparity in how CMS rewards quality between MA and ACOs. MA plans are rewarded bonuses for high quality. ACOs are not.”
The quality payment program impacts the entire healthcare industry including that of private payers. Health insurance companies will need to address provider concerns about MACRA regulation and its administrative burden. For example, commercial payers may need to align their efforts with CMS in creating similar value-based care structures and alternative payment models in order to reduce physician burden in quality reporting.
Dr. Farzad Mostashari, Founder of Aledade Inc. and former National Coordinator for Health IT, recently told HealthPayerIntelligence.com that commercial payers need to catch up to CMS in helping providers contract through alternative payment models.
“I see some positive trends just in the past two years, but private payers, by and large, are still behind CMS in terms of making it easy for organizations to apply for and qualify for these models,” Mostashari said.
“Medicare has an application process that is complicated but predictable whereas with many private payers, the process itself is opaque and the outcome uncertain,” Mostashari continued. “I would strongly suggest that private payers institute more predictable processes and requirements as well as boilerplate contracts that are based off of CMS templates and a clear process for how organizations can apply for and get those risk, value-based contracts.”
CMS has gone forward with creating a quality payment program that alleviates some regulatory burdens that allow smaller medical practices to stay competitive. As such, market consolidation should not be on the rise and provider competition should still be strong, he explained. Both public and private payers benefit from high levels of provider competition.
To further alleviate physicians’ administrative burdens, commercial payers may need to follow the multi-platform quality reporting capabilities CMS has offered to providers as well as invest more resources in expanding alternative payment models.
The MACRA quality payment program may also be helpful to private payers looking to partner with ambitious and high-quality healthcare providers. The quality payment program offers commercial payers a multitude of data on the quality of their provider networks and the benchmarks they’ve reached. With such data, payers can find the best hospitals and clinics to partner with.
Private payers are advised to use MACRA regulations and the quality payment program to advance alternative payment models in their practice as well as alleviate providers’ administrative burden in quality reporting.