CMS closed the comment period Monday for its 2018 proposed rule for the Medicare Access and CHIP Reauthorization Act's Quality Payment Program.
Here are comments on the proposal from five industry organizations.
1. The Federation of American Hospitals lauded the "glide path" to ramping up clinician participation in the proposed rule. FAH said it supported raising the low-volume threshold for participation in the Merit-based Incentive Payment System, the additional flexibility for hospital-based physicians and bonus points for small provider practices' complex patients. It suggested allowing low-volume clinicians to opt-in to MIPS participation, adding bonus points for rural providers and increasing educational resources and feedback.
As for the Advanced Alternative Payment Model, FAH felt more options should be made available, but that CMS should be cautious about counting Medicare Advantage toward Advanced APM participation.
2. The American Medical Group Association was more critical of the proposed rule, as it would slow the transition to value-based care. In particular, AMGA was critical of the proposed exclusion of MA from Advanced APMs, the decision to determine on an individual basis if physicians qualified for all-payer APMs and the increase in the low-volume threshold for MIPS.
"In a well-intentioned effort to make the transition to value-based care as smooth as possible, CMS is delaying this transition," Ryan O'Connor, AMGA's interim president and CEO, said in a statement. "Excluding two-thirds of providers from the MIPS program does not meet Congress' goal to transform Medicare into a value-based purchaser of care."
3. The American Medical Association felt CMS' proposal was an improvement as physicians work to adjust to the program's changes, but sought additional paths to simplify the program and additional opportunities for Advanced APM participation.
"When physicians are asked to move to a new program, we expect some bumps along the way. CMS has been a good partner in smoothing out the bumps but the program still needs to be more understandable and less burdensome," AMA President David Barbe, MD, said in a statement. "The complexity is an obstacle to the goal of promoting innovative approaches to encourage higher value care. We applaud CMS' decision to allow for another transition year for MIPS, recognizing the challenges physicians face both bureaucratic and technological. The willingness to compromise will help physicians and patients alike."
4. The American Hospital Association applauded the flexibilities added for hospital-based physicians and the slower path to adoption allowed by the proposed rule. "However, we urge CMS to better align the meaningful use requirements of EHRs for hospitals with those of clinicians, enhance its approaches to risk adjustment and provide additional opportunities for clinicians to earn incentives for collaborating with hospitals to enhance the quality and efficiency of care through APMs," Ashley Thompson, AHA senior vice president for public policy analysis and development, wrote in the AHA letter to CMS.
5. Utilization Review Accreditation Commission, an accreditation organization that certifies patient-centered medical homes, said it supported the slower implementation in CMS' proposed rule, as well as the changes to help even the playing field for small practices. "We believe that many of the changes in the proposed rule, including bonus points for small practices, are positive steps; but more must be done to promote the types of changes within these practices required for success in a value-based reimbursement system," the URAC letter to CMS read.
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