Premier Inc. Statement on the Proposed Regulation to Implement the Medicare Access and CHIP Reauthorization -Act of 2015 (MACRA) Last Updated: April 28, 2016
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By Blair Childs, Senior Vice President of Public Affairs, Premier

Members of the Premier alliance believe that the Centers for Medicare & Medicaid Services (CMS) has made a significant mistake by not including any bundled payment or Track 1 Medicare Shared Savings Program (MSSP) ACOs as qualifying advanced payment models (APMs) under MACRA.

Rather than rejecting bundled payment programs, we believe CMS should focus on ways to alter the bundled payment programs to demonstrate use of certified EHR technology and align measures with other APMs. We also believe CMS seriously erred in excluding Track 1 MSSP ACOs in the APMs for failing to meet the more than “nominal risk” financial requirement. As we have learned through members in our population health management collaborative, these programs require providers to not only forego revenue through a lower volume of services, but also invest millions of dollars in redesigning care through new technologies, data analytics, additional staff, etc. We think most businessmen would call that more than nominal risk, yet CMS chose to define it as only cases where there is risk to the government.

In not recognizing Track 1 ACOs and bundled payment options as APMs, the proposed rule could have the unintended consequence of waiving physicians off the APM path in favor of fee-for-service. This undermines the very intent of MACRA to incent providers to move to value-based payment models.

Blair Childs, Senior Vice President of Public Affairs, Premier Inc.