CMS has issued the 2018 final rule for the Medicare Access and CHIP Reauthorization Act's Quality Payment Program.
Here is how the industry reacted to the final rule.
1. Nelly Ganesan, senior director at consulting firm Avalere Health, responded positively. The "final rule reflects the administration's continued commitment to providing flexible participation options for clinicians. We expect CMS will continue to seek input on implementation and execution of program elements," Ms. Ganesan said.
2. Tim Gronniger, former CMS deputy chief of staff and senior vice president of strategy and development at Caravan Health, a consultant, presented a mixed reaction. "The final rule for 2018 makes clear that for the vast majority of clinicians MACRA is here to stay, so it's time to start planning for how to succeed rather than hoping CMS makes it all go away," Mr. Gronniger said. "While we would have preferred CMS not increase the low-volume threshold, clinicians who see any significant number of Medicare patients are still in the program, and clinicians who are excluded will see their compensation frozen for the coming five years."
3. AMGA President and CEO Jerry Penso, MD, expressed concerns about the final rule. "The transition to value is challenging and CMS understandably wants to ease providers into value," Dr. Penso said. "But excluding providers isn't the same as learning how to deliver care in a value-based world. Taking accountability for the quality and cost of care requires years of experience. Despite CMS' intentions to ensure a smooth transition, AMGA is concerned that this rule actually hinders the prospects for value-based care."
4. Blair Childs, senior vice president of public affairs for Premier, a healthcare solutions firm, praised some parts of the final rule but expressed disappointment in other aspects. "Premier and its members commend CMS for allowing individual or small group practice clinicians to join virtual groups as a new channel to participate in" the Merit-based Incentive Payment System," Mr. Childs said.
"We are also encouraged that CMS indicated its intention to develop a demonstration project to examine how clinicians participating in Medicare Advantage alternative payment models can qualify for bonus payments. Nearly one-third of Medicare beneficiaries are enrolled in an MA plan. Many MA plans have engaged providers in innovative value-based contracts that are benefiting patients. This policy would level the playing field for clinicians in areas with high MA penetration.
"However, Premier and its members are disappointed with CMS' decision to cut payment rates for nonexcepted, off-campus, provider-based hospital departments by an additional 10 percentage points, from 50 to 40 percent. Basing this decision on an evaluation of a single code is unjustified and fails to reflect the higher costs that these sites incur relative to freestanding physician offices. This decision will reverse momentum toward providing care across the continuum."
5. Tom Nickels, executive vice president of government relations and public policy at the American Hospital Association, felt the final rule "continues a flexible approach to the MACRA's physician quality payment program urged by hospitals, health systems, and the more than 500,000 employed and contracted physicians with whom they partner to deliver care."
"While we believe it could be adopted in 2018, we understand CMS' decision to eventually adopt a facility-based clinician measurement option that will allow many hospitals and clinicians to spend less time collecting data, and more time collaborating to improve care," Mr. Nickels said. "While we applaud CMS for providing much-needed relief from unrealistic and unfunded mandates for EHR capabilities for clinicians, we are disappointed the agency has yet to provide similar relief for hospitals. We also urge CMS to provide additional avenues for clinicians to earn incentives for partnering with hospitals to provide better quality, more efficient care through advanced alternative payment models."
6. Anders Gilberg, senior vice president of government affairs at the Medical Group Management Association, expressed disappointment. "MGMA is very disappointed that CMS quadrupled the length of the quality reporting period under MIPS from the current 90 days to 365 days in 2018," he said. "This fourfold increase to the quality reporting requirements is in stark contrast the agency’s statements ... that the final rule reduces regulatory burdens. CMS is in effect prioritizing quantity over quality and giving physicians less than 60 days to prepare for the 2018 MIPS requirements."
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