MACRA Implementation

AGA POSITION: Congress must monitor MACRA implementation to ensure the intent of the law is realized.

AGA appreciates that Congress passed, and the president signed into law, the Medicare Access and CHIP Reauthorization Act (MACRA; P.L. 11410) in April 2015. MACRA replaced the flawed sustainable growth rate (SGR) formula with the Quality Payment Program (QPP), which represents a new more streamlined approach to paying providers for the value and quality of their care through the Merit-based Incentive Payment System (MIPS) and other alternative payment models (APMs). On April 27, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule implementing the QPP. The final rule is expected to be published by Nov. 1, 2016, for implementation on Jan. 1, 2017. 

MACRA Implementation Changes

AGA appreciates CMS’ recent announcement that they will provide physicians with four reporting options in the first year of MACRA to provide greater flexibility and the opportunity to succeed under the new payment law. These options reflect the concerns that have been expressed by AGA, the physician community and Congress.

CMS Acting Administrator Andy Slavitt announced that the agency will give physicians four reporting options:

Option 1: A new test option allows physicians to report some data after Jan. 1, 2017. This option will give providers time to prepare for additional reporting beginning in 2018.

Option 2: Providers can submit data to QPP for a reduced period, which has not been defined by CMS, and not the full calendar year, as was originally proposed. This option will allow the first performance period to begin later than Jan. 1, 2017, and physicians may potentially earn a small bonus.

Option 3: Providers can submit data to the QPP for a full calendar year starting Jan. 1, 2017, which would include quality measures, certified health information technology and clinical practice improvement activities. Providers that are prepared to report for a full year are eligible for positive payment adjustments.

Option 4: Providers can participate in advanced alternative payment models (APMs) and be eligible for a 5 percent bonus payment.

AGA is pleased that CMS is providing physicians with more flexible options for reporting and that, most importantly, no physician will be penalized in 2019 for their reporting in 2017.  

Gastroenterology Develops Innovative Payment Models

Gastroenterologists have been at the cutting edge of payment and delivery reform. As a community, we have worked with payors and other providers — both primary care and specialists — to develop innovative tools to improve quality of care and reduce costs. These efforts involve bundled payment initiatives for common procedures and conditions, such as colonoscopy and obesity, as well as episodic payment for gastroesophageal reflux disease. All of these initiatives have the potential to benefit both private payors and the Medicare program, provided that CMS allows flexibility for new payment models.  

Innovation from the gastroenterology community makes the restrictive proposals contained in the proposed MACRA rule very troubling. Despite the valuable work from specialty physicians to advance payment reform, the CMS proposal minimizes our role in reform and innovation, which is likely to severely restrict the participation of specialists in APMs. Given the work that we have already invested and the expertise that we bring to the table, CMS should ensure that APMs and physician-focused payment models provide substantial opportunities for gastroenterologists. Without the inclusion of specialty physicians, payment reform models are likely to be unsuccessful and will exclude the highest cost, most complicated patient mixes.  

Call to Action: MACRA Needs to be Implemented Fairly 

AGA appreciates the flexibility that CMS has announced in providing physicians with different reporting options to help ease the transition to MACRA in the first year. We believe these changes will help physicians to successfully comply with the new requirements under the QPP. In addition to ensuring that specialty-focused payment models are treated equitably under MACRA, AGA asks Congress to require CMS to provide more flexibility for small and solo practices.

Provide Flexibility for Small Practices. While the new reporting options will give small or solo practices greater flexibility to comply with the MIPS reporting requirements, other steps should be taken to ensure that all physicians, regardless of their specialty or practice size, have an equal opportunity to succeed in this new program. A positive step in this direction would be for CMS to raise the MIPS low-volume exclusion threshold to $75,000 in Medicare allowed charges or fewer than 100 Medicare patients seen by the physician. Additionally, CMS should provide guidance for the establishment of “virtual groups” as quickly as possible.

Specialty Physician-Focused Payment Models. MACRA encourages the development of specialty-specific Physician-Focused Payment Models (PFPMs). However, the review criteria that will be employed by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) does not facilitate a high degree of engagement with specialty medicine providers on specialty-focused models. AGA asks Congress to closely monitor the PTAC review process to ensure the advancement of specialty-focused PFPMs, as was intended under the law.

September 2016