MACRA Proposal Comment Period Draws Suggestions From Groups, Individual Providers

With the comment period now concluded, CMS has received nearly 1300 comments on its proposed amendments to the Quality Payment Program established by the Medicare Access and CHIP Reauthorization Act (MACRA).

CMS has received nearly 1300 comments on its proposed amendments to the Quality Payment Program (QPP) established by the Medicare Access and CHIP Reauthorization Act (MACRA). The comments reflected praise, concerns, and suggestions from interested stakeholders, including individual physicians, specialty groups, and large physician organizations.

The updates to the QPP were announced in June, after CMS received feedback from clinicians worried about potentially burdensome requirements. In response, it decided to raise its low-volume thresholds to exempt more practitioners and announced it would allow small practices to join “virtual groups” for reporting, among other tweaks. The proposal allowed for comments until August 21.

Some of the largest physician organizations in the country have taken advantage of this comment period, including the American Medical Association (AMA) and American Hospital Association (AHA). The AMA’s letter acknowledged the QPP had been improved by the amendments, but called on CMS to “simplify and further streamline the program” by modifying its quality performance methodology and recommended other updates. The AHA also applauded the amendments while urging further changes, including aligning electronic health record use requirements for hospitals with those of clinicians.

Specialty medical societies also offered comments on how the proposed rule would impact their members and patients. The American Society of Clinical Oncology raised concerns that using cost-effectiveness data in performance scoring for the QPP’s Merit-based Incentive Payment System (MIPS) track could punish oncologists who treat patients with expensive, but necessary, specialty cancer therapies. Instead, it suggested measuring adherence to oncology clinical pathways as a fairer way to ensure value.

Additionally, individuals took to the comment field to offer recommendations and opinions informed by their clinical experiences. For instance, Harrison Alter, who identified himself as an emergency physician in California, suggested adding a MIPS Improvement Activity based on “screening for health-harming legal needs,” citing the case of a patient who needed legal assistance to force her landlord to remove the mold in her apartment that caused her recurrent asthma.

Many individuals submitted the comment suggested by the Physician Assistant Education Association, which voiced support for a provision that would grant quality measurement points to MIPS-eligible practitioners who serve as preceptors for clinicians in training, including physician assistants. The comment explained that this would help alleviate the provider shortage, particularly if the provision expands the number of clinical training sites allowed.

A frequent theme throughout the comments was the complaint of over-regulation. “Compliance with MACRA is not compatible with patient-centered care,” wrote C. Peterson of Oregon, a self-described physician and Medicare patient, in one such comment. “It is also likely to increase the cost of care delivery, and on the backs of small practices since it is budget-neutral.” Many of these comments called for exempting practices with 15 or fewer physicians from MACRA’s requirements.

CMS will now consider these comments as it works to finalize the changes to the QPP. Because 2017 is considered a transition year, the updates will go into effect in 2018, Year 2 of the QPP.

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