AMGA provides comments on MACRA implementation

AMGA today recommended that the Centers for Medicare and Medicaid Services (CMS) increase possible pathways to participate in Medicare as an advanced Alternative Payment Model (APM) in written comments on the  proposed rule implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In addition, AMGA addressed many other issues, including the restrictions on qualifying as an advanced APM, risk adjustment and resource use measurement under the Merit-Based Incentive Payment System (MIPS), and the importance of considering outcomes when determining value in health care.

Among AMGA’s main issues was the timeframe for implementation. AMGA is concerned that eligible clinicians and medical groups will not have sufficient time to review and select appropriate quality measures and make the health information technology (HIT) changes necessary to succeed under MIPS. AMGA is recommending that the MACRA start date be delayed until July 1, 2017.

“CMS has proposed an aggressive timeframe in this rule,” said Donald W. Fisher, Ph.D., CAE, AMGA’s president and chief executive officer. “The requirements in this rule must be carefully considered. Finalizing the rules of a new program in November and expecting providers to be ready in January is unrealistic.”

AMGA also recommended that CMS develop pathways for Track 1 Accountable Care Organizations (ACOs) to qualify as advanced APMs and for Medicare Advantage (MA) participants to qualify under the all-payer category beginning in performance year 2019.

“AMGA recommendations will allow greater participation under MACRA as advanced APMs,” Fisher said. “Allowing more Track 1 ACOs to qualify will improve care and strengthen the Medicare Shared Savings Program.  Allowing MA payments will help group practices qualify as advanced APMs and further efforts to a value-based payment system.” 

Read AMGA’s comments.

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