Our MACRA Comments Are In

August 22, 2017 · Amy Maciejowski

The comment period for MACRA’s 2018 proposed rule closed yesterday. As you know, we’ve watched MACRA closely. Our public policy team read through the proposal and evaluated all the changes. We submitted comments to the Centers for Medicare and Medicaid Services (CMS). Here are some key points we commented on:

• Virtual groups. Although the virtual groups have been hinted at for some time, the 2018 proposed rule detailed how they would work. We are extremely enthusiastic about this option, as it will benefit small and rural practices.
  • What we’d like to see: CMS should encourage, rather than prohibit, low-volume clinicians’ participation in virtual groups. We don’t think the thresholds should deter small and rural practices from banding together to join a virtual group. Read more here.
• Patient-Centered Connected Care. In the 2018 proposed rule, our recognized Patient-Centered Connected Care practices are designated as one of the Improvement Activities for the Merit-Based Inceptive Payment System (MIPS). This means NCQA-Recognized Connected Care practices can use recognition to fulfill part of their Improvement Activity points for that category. The Connected Care program promotes coordinated care for urgent, retail, workplace and other independent clinics.
  • What we’d like to see: Our Connected Care practices follow rigorous guidelines to become recognized. Our program requires practices to focus on care coordination, evidence-based decision support, access to care and culturally and linguistically appropriate services. They deserve a high-weighted Improvement Activity status. Right now, their recognition only fulfills part of the Improvement Activity category. Connected Care recognition should give practices automatic credit for this category.
• Advancing Care Information. More great news for our Patient-Centered Connected Care recognized practices- they receive Advancing Care Information (ACI) credit for their use of Health IT within the program. We are thrilled to see this in the 2018 rule as it reduces extra work for our practices.
  • What we’d like to see: This ACI auto-credit for Connected Care begs the question- why not offer it to our PCMH and PCSP practices? Our PCMH and PCSP programs include a strong focus on Health IT within our standards. In fact, our crosswalk shows a substantial overlap between what we require of our recognized practices and the ACI requirements and measures. This auto-credit will reduce burden for our practices. Read more on our strategy here.
• Quality Measure Data Completeness. In 2018, CMS raised the measure data completeness requirement to at least 50% of all eligible patients per measure. We think this increase is a good start.
  • What we’d like to see: This percent should steadily increase. CMS should consider raising it further to 60% for CY 2018 and continue to do so over time. Eventually, getting practices to report 100% of their eligible patients. This is crucial to identify “topped out” measures and prevent gaming of measures. Making reporting of core population-based measure sets mandatory makes results more actionable. For example, Medication Reconciliation in PQRS consistently produces rates above 95%. However, the same plan-level measure in HEDIS (where reporting is mandatory) has a performance rate of about 46%.

More Requested Changes

We just gave you a snapshot of our comments to CMS. You can read the rest here.

NOTE: If you haven’t checked out our MACRA toolkit, you can learn more about it here.