Premier submitted comments on the Medicare Access and CHIP Reauthorization Act (MACRA) proposed rule, which can be downloaded here.
Following are some of the key points Premier made in its letter.
Merit-Based Incentive Payment System (MIPS)
- Quality measure domain (50% weighted): We support CMS’ proposed reduction in measures from 9 to 6 and recommend that CMS reduce the data completeness requirements in 2017. We also oppose use of the AHRQ PQI measures the all-cause readmission measure over concerns with its validity and reliability. We support awarding bonus points for high-priority measures and suggests stronger incentives by increasing the maximum bonus points to 10 percent of the total possible score.
- Resource Use (10%): We urge CMS to allow clinicians to use only total costs or condition-specific episodes, submit all of the measures for NQF approval, and make adjustments for socio-demographic factors.
Clinical Practice Improvement Activities (15%): We recommend that CMS modify the scoring so that clinicians complete only two to four activities per year and one activity per year for small, rural and Health Professional Shortage Areas (HPSA).
- Advancing Care Information (25%): In this formerly “Meaningful Use” measurement category, we support the approach to recognizing levels of achievement rather than an all or nothing approach. We propose CMS provide more bonus points for optional registry reporting and urge the use of benchmarks and deciles to award performance points.
MIPS APM Scoring Standard
We ask that CMS allow facility-led APMs to use the APM scoring standard. We also ask CMS to create a pathway for models that do not directly tie clinician quality performance to payment but do so through a facility measure. We also emphasize that CMS needs to provide feedback on performance earlier during the performance year, particularly for claims-based measures.
APM 5% Incentive payment system
- We strongly urge CMS to implement new Advanced APMs eligible for the bonus payment.
- Medical home model definition: We support the choice of 4 out of the 7 proposed discretionary elements that qualify a medical home model and asks CMS to consider incorporation of specialists who act as the primary care provider for patients within the medical home.
- Advanced APM Criteria, financial risk for monetary losses: We ask CMS to reconsider investment risk for what constitutes “nominal financial risk,” at least until a lesser risk track can be developed and implemented in the Medicare Shared Savings Program (MSSP). We also recommend CMS lower the proposed loss sharing limit for Advanced APMs from 4% to a reasonable threshold such as 10% of Part B professional services or 1% of total Part A and B costs.
- Capitation: We support making full capitation risk arrangements qualify as an Advanced APM and encourage including partial capitation.
- Application of criteria to bundled payment: We recommend that Comprehensive Care for Joint Replacement (CJR) and Bundled Payment for Care Improvement (BPCI) models count as Advanced APMs.
- Other-Payer Advanced APM Models: We ask that the recommendations in our letter be applied to the Other-Payer Advanced APMS and that there be some flexibility on quality and CERHT requirements that are fitting for the population and payment models.