The Alliance of Specialty Medicine submitted a statement for the record at the US Senate Finance Committee′s hearing on implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). In the statement, the Alliance makes the following recommendations:
- CMS should modify the initial start date of MIPS so physicians and practices have adequate time to prepare for the new program. MIPS should start no earlier than July 1, 2017, allowing CMS to establish a shorter performance period in the first year of the QPP program — such as a 6-month performance period, with an optional “look-back” to January 1 in 2017.
- CMS should minimize the reporting burden, particularly during the initial transition period, by maintaining the current PQRS reporting thresholds. Additionally, CMS should retain measures groups.
- The cost and resource use measures are completely flawed and inadequate. As such, CMS should use its authority under MACRA to re-weight this category to zero.
- There are very few activities that create a pathway for specialists to earn credit for their engagement in clinical practice improvement activities, and it is essential that CMS expand its list of recognized activities for this MIPS category.
- CMS should eliminate the “all or nothing” scoring in the electronic health record (now known as “advancing care information”) category.
- The proposed QPP largely retains the flawed siloed approach of Medicare’s current quality improvement programs and its scoring system is extremely complex. CMS should, therefore, rethink its scoring methodology and make modifications that would standardize, streamline, and maintain consistency so that MIPS eligible clinicians are able to understand and respond appropriately.
- We continue to be frustrated by the lack of APM participation options available to specialty physicians.
- CMS must establish a mechanism for distinguishing subspecialties to ensure that smaller subspecialties are not disadvantaged by the QPP and its scoring methodology.