CMS Proposes Amending MACRA Rules to Alleviate Physician Burden, Exempt More Practices in 2018

In response to trepidation from clinicians, CMS has proposed altering the rules of the Quality Payment Program (QPP) established by the Medicare Access and CHIP Reauthorization Act (MACRA). The changes will exempt thousands of physicians from quality reporting requirements and allow small practices to form “virtual groups” with one another.

The updates will go into effect in 2018, the second year of the QPP, as 2017 is designated as a transition year. The changes mainly concern the QPP’s Merit-based Incentive Payment System (MIPS) track, although there were some updates affecting the Advanced Alternative Payment Model (APM) options.

In a document outlining the updated proposed rule for Year 2, CMS explained that it “wants to keep what’s working and use stakeholder and clinician feedback to improve the policies finalized in the transition year.” The most notable changes to MIPS are as follows:

• Solo practitioners and small practices can band together to form “virtual groups” for reporting metrics
• The low-volume thresholds are increased from $30,000 to $90,000 in Part B charges and from 100 to 200 Part B beneficiaries, exempting about 134,000 more clinicians from participating
• Extra points will be awarded to practices that care for complex patients or use only the 2015 edition of Certified Electronic Health Record Technology (CEHRT)
• Quality performance scores will include a measure of MIPS performance improvement

There are also several changes targeted at small practices in particular, like allowing clinicians to claim a hardship exception from the Advancing Care Information measurements, awarding bonus points to small practices’ final scores, and granting points for certain measures even if they do not meet the data completeness requirements.

Tweaks to the Advanced APM track policies included changes to the minimum required total risk amounts for Medical Home Models. Additionally, APMs bearing total risk of 8% of their Medicare Parts A and B revenue originally could only qualify as Advanced APMs through 2018, but this standard has now been extended through 2020.

The press announcement from CMS described the changes as a response to the feedback gathered from physicians.

“We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient. That’s why we’re taking a hard look at reducing burdens,” said administrator Seema Verma. “By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork.”

Physician groups like the American Medical Association (AMA) applauded the amendments, saying that they demonstrated the administration’s willingness to listen to the voices of clinicians.

“Not all physicians and their practices were ready to make the leap, and many faced daunting challenges,” said AMA president David O. Barbe, MD, in a press statement. “This flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country.”

Some reactions focused on the implications for health information technology (IT), such as the steps taken to encourage the move to the new 2015 CEHRT and the inclusion of more health IT-related metrics that can apply towards bonus performance payments.

“It is vital that we continue our collective march towards modernizing healthcare delivery and the patient’s experience,” said Douglas B. Fridsma, MD, PhD, FACP, FACMI, president and CEO of the American Medical Informatics Association (AMIA), in a statement. “While there are numerous details to review, AMIA is pleased that CMS has proposed a flexible set of requirements meant to encourage health IT-enabled care.”

The praise, however, was not unanimous, as some organizations complained that the changes would result in a watered down QPP and were unfair to groups that had already transformed their practices in order to comply with MACRA.

“If CMS wants to transition to value-based payment for care, the program needs to be fully implemented. We recommend that CMS revise its proposal to fully incentivize high performers in the Medicare program,” said Chester A. Speed, JD, LLM, vice president of public policy of the American Medical Group Association (AMGA), in a press release. “AMGA members have already started on this journey, and they should be recognized for being leaders in healthcare.”

CMS will accept comments on the proposed rule until August 21, 2017.