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Alliance Letter to CMS on MACRA Implementation

06/28/2016

The Alliance of Specialty Medicine wrote to the Centers for Medicare and Medicaid Services (CMS) outlining its concerns with the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA).  The concerns the Alliance has with MACRA include:

MIPS Performance Period/Reporting Burden.  The Alliance asks Congress to require CMS to delay and provide a shorter performance period in 2017 (such as a 6-month performance period) (with an optional “look-back” to January 1 in 2017) for the first MIPS payment adjustment in 2019. CMS has underestimated the time and resources required to engage in current and future quality reporting programs. Since MIPS incorporates additional elements of accountability, CMS must minimize provider burden to the greatest extent possible. 

Robust education.  The Alliance requests that CMS continue providing robust education through a variety of media, including: webinars and audio conferences, easy-to-read and search Frequently Asked Questions (FAQs), simple process diagrams, flowcharts and other tools to help providers understand their options, telephonic and email hotlines with hours extended beyond regular office hours, specialty society-focused education, educational tools aimed specifically at practice administrators, and use of Quality Improvement Organizations (QIOs) to assist in technical assistance outreach.

Key fundsUnder MACRA, Congress authorized funding for measurement development activities, and these funds have been appropriated and dispersed to CMS. The Alliance is frustrated that these monies have not yet been distributed, despite CMS’ awareness that measure development activities take a significant amount of time, anywhere from 18- to 36-months. Given existing measurement gaps within specialty medicine,  CMS needs to release the quality measure development funding immediately before even more time is lost.

Specialty PFPMs. MACRA encourages the development of specialty-specific Physician-Focused Payment Models (PFPMs), however, the review criteria that will be employed by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) does not facilitate a high degree of engagement with specialty medicine providers on specialty-focused models. The Alliance asks the Congress to closely monitor the PTAC review process to assure the advancement of specialty-focused PFPMs, as was intended under the law.  

 Click here to read the letter.

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