NCQA Files Comments on MACRA Final Rule

December 15, 2016 · Amy Maciejowski

Ever since the release of MACRA final rule in November, it’s been MACRA mania in the NCQA offices. The bipartisan regulation supports the transition to paying clinicians for the value, rather than the volume, of care they provide. It’s been an exciting time to read over the final rule and evaluate its impact on the future of value-based payment.

The Centers for Medicare and Medicaid Services (CMS) is accepting comments on the final rule on MACRA. As a leading measure developer, we filed comments on CMS’ welcome shift to a more value-based system for Medicare.

In short, we believe CMS should:

• Move beyond simple and meaningless attestation for PCMH or PCSP to require independent, verifiable recognition for automatic Improvement Activities credit.
• Establish significantly more rigorous criteria for quality measures tied to payment under the Merit-Based Incentive Payment System (MIPS).
• Develop a framework for Virtual Groups so clinicians can prepare for joint accountability and participation in Advanced APMs.
• Address remaining concerns about small and rural practices. One such approach NCQA recommends is to stratify practices by size for MIPS reporting and comparison purposes.
• Evolve Advancing Care Information (ACI) measures to make continued progress on patient engagement, care coordination, and interoperability objectives.

Overall, we believe the highest priority for implementation should be to help clinicians advance from traditional practice to accountable, team-based, and patient-centered models of care. CMS must provide a clear pathway for clinicians to move along the continuum from unorganized delivery to Patient-Centered Medical Homes (PCMHs) and Patient-Centered Specialty Practices (PCSPs), virtual groups and ultimately to Alternative Payment Models (APMs). NCQA is committed to working with CMS and other stakeholders to support clinicians throughout this essential transformation.

We agree that flexibility (the “Pick Your Pace” options) in the initial transition year is critical to protecting the viability of practices – particularly those that are small and/or in rural settings. We have concerns, however, that the progress achieved through passage of MACRA could be undermined by continuing to delay full implementation of the law. We urge CMS to maintain the proposed timeline and reach full implementation of the Quality Payment Program (QPP) no later than 2019.

We detail these and other important priorities in our comments. You can read our full comment letter below, or here.