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How the 'Doc Fix' Will Affect Nurses, Other Providers

Analysis  |  By Jennifer Thew RN  
   October 25, 2016

As nursing organizations review the 2,400-page final rule, some are calling on CMS to clarify the implications for APRNs.

Sometimes called the "doc fix," the Medicare Access and CHIP Reauthorization Act (MACRA) will affect other healthcare providers as well, including advanced practice registered nurses, physician assistants, and physical therapists.

While many nursing organizations are still reviewing the 2,400-page final rule, several have issued comments.


MACRA Final Rule Eases Pay Changes, Initially


The American Association of Nurse Anesthetists is in the process of reviewing the final rule, and looks forward to working with CMS to assure that certified registered nurse anesthetists have the opportunity to be competitive participants in this program, officials said.

The American Association of Nurse Practitioners officials noted the MACRA rule is approximately 2,400 pages long, and is still being reviewed by the association's Federal Government Affairs team. "We are unable to provide a comment at this time," the AANP stated.

The American Nurses Association submitted comments on the proposed rule in June. "While we continue reviewing the 2,398-page document, it appears that many of the concerns articulated in ANA's comment letter did not result in corresponding changes from the proposed to final regulation," the organization stated.

ANA raised issues related to restrictions on non-physician data input observed in some certified electronic health records, attribution of the services of advanced practice registered nurses billed "incident to," and restrictive APRN credentialing practices observed in many health plans and anticipated with respect to some Alternative Payment Model plans, the group stated.

"ANA looks forward to an ongoing … dialog with CMS regarding the concerns of APRNs enrolled as Part B providers as well as the important role registered nurses provide to Medicare beneficiaries as well all of patients these front line providers care for."

The American Organization of Nurse Executives did not issue a separate comment on the final rule but referred to The American Hospital Association's statement by Tom Nickels, executive vice president, government relations and public policy at AHA. AONE is a subsidiary of AHA.

"[The] final MACRA rule presents challenges and opportunities for hospitals and health systems, and the nearly 540,000 directly employed or contracted physicians with whom they partner to deliver quality care.

AHA is disappointed that CMS continues to narrowly define advanced APMs, which means less than 10% of clinicians will be rewarded for their care transformation efforts, but is encouraged that CMS is exploring a new option that would expand the available advanced APMs that qualify for incentives, Nickels wrote.

"We urge CMS to ensure that this option be available in 2017 and look forward to working with them so this new model achieves an appropriate balance between risk and reward."

The AHA lauded CMS for provided clinicians increased flexibility to meet MACRA's aggressive timelines and reporting requirements. Allowing clinicians in a variety of settings to "pick their pace" will enable them to more easily transition to the new program.

The final measures in the Advancing Care Information section are a welcome step back from the "overly aggressive" initial proposal, but the AHA is concerned that the lack of sociodemographic adjustment to the measures used in the MIPS will unfairly burden clinicians and hospitals caring for the poorest patients, Nickels wrote.

National Association of Clinical Nurse Specialists has not issued a formal statement on the new rule.


Tech Remedies for Regulatory Compliance


CMS has announced its intent to expand opportunities for clinicians to participate in advanced APMs by retrofitting existing models to qualify as advanced APMs. The organization also intends to use the CMS Innovation Center to create new models.

The U.S. Department of Health & Human Services encourages feedback on the final rule and will accept comments until December 17. Comments can be submitted through the e-Regulation website.

Jennifer Thew, RN, is the senior nursing editor at HealthLeaders.

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