Reaction to CMS's proposed rule includes a claim from MGMA that the proposal "provides almost no opportunities for medical groups to begin the shift away from fee-for-service reimbursement."
Physicians may not despise (MACRA) as much as they did the sustainable growth rate (SGR) formula, but the Centers for Medicare & Medicaid Services' proposed rule for implementation of the Medicare Access and Children's Health Insurance Program Reauthorization Act isn't winning any popularity contests.
Emblematic of how physicians responded were the comments left by Charles A. Adams, Jr., MD. "While anything that did away with the flawed and completely ineffective SGR should be an improvement, adoption of MACRA will likely not have the desired effect that it hopes to realize," he wrote.
In all, more than 1,200 comments were submitted by individuals, hospital and physician groups, and consumer advocates.
The American Hospital Association
"The AHA is extremely disappointed that few of the models in which hospitals have engaged will qualify as advanced alternative payment models (APMs); we urge CMS to adopt a more inclusive approach," said the American Hospital Association in its comments.
"Specifically, we are concerned that CMS's proposed approach fails to recognize the significant resources providers invest in the development of APMs, because under the proposal, an APM generally must require participating entities to accept significant downside risk to qualify as an advanced APM."
Major physician organizations, including the American Academy of Family Physicians (AAFP), voiced concerns about the proposed pace of implementation.
"While our support for MACRA remains strong, we must state that we see a strong and definite need and opportunity for CMS to step back and reconsider the approach to this proposed rule which we view as overly complex and burdensome to our members and indeed for all physicians," the AAFP wrote in a 107-page letter to CMS Acting Administrator Andrew Slavitt.
"Given the significant complexity of the rule, we strongly encourage CMS to issue an interim final rule with comment period rather than to issue a final rule."
The American Medical Association also called for an interim final rule.
"Under MACRA, high-quality, high-value care and improved health outcomes for patients will be rewarded, but ensuring a smooth transition away from SGR requires up-front work today," said AMA president Andrew W. Gurman, MD.
The rule's timing and complexity are key complaints among specialty groups as well.
The American College of Rheumatology (ACR), for example, argued that most rheumatologists wouldn't be able to comply with the law's requirements under the proposed timeline.
In a joint statement, the American Association of Neurological Surgeons (AANS) and Congress of Neurological Surgeons (CNS) called the timeline to implement MACRA "overly ambitious" and recommended the initial performance period be delayed from January 1 to no earlier than July 1, 2017, "but ideally not until Jan. 1, 2018."
AANS and CNS also called for participation in a qualified clinical data registry to automatically satisfy multiple Merit-based Incentive Payment System (MIPS) categories, including quality, clinical practice improvement activities, and advancing care information—the MACRA replacement for the meaningful use program for physician practices.
The majority of physician practices with fewer than 25 clinicians, which reflect most neurosurgical practices, will receive negative payment adjustments under the proposed rule, AANS and CNS said.
The two organizations suggested CMS raise the MIPS low-volume exclusion threshold to $30,000 in charges allowed by Medicare, or for practices seeing fewer than 100 Medicare patients.