June 28, 2016
WASHINGTON, DC—In comments filed in response to the proposed rule implementing the Medicare Access & CHIP Reauthorization Act (MACRA), the National Committee for Quality Assurance (NCQA) reiterates its strong support for the law, while recommending the final rule lay out a clear path for how clinicians can advance into more organized delivery systems with greater quality improvement potential.
“The highest priority in MACRA is to help clinicians advance from traditional practices into Patient-Centered Medical Homes (PCMHs) and Patient-Centered Specialty Practices (PCSPs), virtual groups and ultimately Alternative Payment Models (APMs),” says Margaret E. O’Kane, President, NCQA. “Each step along this continuum increases clinicians’ potential to improve and achieve MACRA’s goals and financial rewards.”
MACRA encodes NCQA’s once-pioneering idea of paying clinicians for the value, rather than volume, of care they provide as law of the land with broad, bipartisan and multi-stakeholder support. NCQA supports many provisions of the law and proposed rules for implementing it. We are particularly pleased that the proposed rule recognizes the importance of PCMH and PCSP recognition from national-in-scope, widely used third party programs. We also support its drive toward more outcome measurement derived from data entered into electronic systems as a natural part of clinical workflow.
NCQA is concerned the proposed rule would:
- Establish insufficient criteria for quality measures that would not drive improvement.
- Unwisely threaten small practices’ viability and their patients’ access to care by comparing them to larger practices with greater abilities to administer improvement programs and earn bonuses.
- Undermine APM viability by basing the amount of financial risk they must share on total care cost rather than their Medicare revenue alone.
- Not support Medicare Advantage and other health plans’ potential to facilitate APM Entities.