By Blair Childs, senior vice president of public affairs, Premier
Members of the Premier alliance strongly support the potential of the Quality Payment Program under the Centers for Medicare & Medicaid Services (CMS) Medicare Access and CHIP Reauthorization Act (MACRA) to help fix the misaligned incentives in our traditional fee-for-service Medicare program. Premier is an ardent supporter of a transition away from fee-for-service and toward a model where providers are accountable and rewarded for high-quality, cost-effective care. CMS wisely allowed a gradual transition to this pay for performance reality, striking a good balance overall.
CMS also did the right thing by creating an accelerated timeline for determining whether clinicians meet the standards for the Advanced Alternative Payment Model (Advanced APM) before the end of the Merit-based Incentive Payment System (MIPS) performance period. This mitigates the uncertainty and added administrative work for ACOs and other organizations who otherwise would have reported through MIPS in the absence of certainty about whether they met the Advanced APM thresholds.
Although CMS eased the policy defining the Advanced APM to allow additional programs to qualify and has signaled it will increase the number of available models, the nominal risk standard remains way too high. As we have learned from members in our Bundled Payment and Population Health Management Collaboratives, these models require significant investment in redesigning care through new technologies, data analytics, and additional staff. CMS has chosen to ignore these realities. We call on CMS to rethink this risk standard in future rules to incent greater participation. We also call on CMS to accelerate recognition of “virtual” physician groups that would allow small practices to band together using technology to meet the minimum thresholds and comply with reporting requirements.
— Blair Childs, senior vice president of public affairs, Premier Inc.