MIPS and APMs
As for the reporting mechanisms themselves, groups generally decried the bars set by both the Merit-Based Incentive System (MIPS) and Alternative Payment Models (APM) as being unrealistically and unnecessarily high.
"Unfortunately, the MIPS/APM proposed rule strays significantly from Congress's intent to simplify quality reporting and provide new value-based opportunities for physicians in Medicare," Halee Fischer-Wright, MD, president and CEO of the Medical Group Management Association (MGMA), said in an media statement.
"The rule's proposed MIPS scoring system is nothing short of a mathematical marvel. Its narrow definition of APM provides almost no opportunities for medical groups to begin the shift away from fee-for-service reimbursement," she said.
Suggestions for Improvement
Among the scores of public comments urging CMS to halt MACRA, MIPS, and APMs altogether, physicians did offer straightforward suggestions for improvement.
"Establish objective and timely measurement and reporting systems that are simpler and less costly than those required under current programs like PQRS and meaningful use," wrote Texas physician John Ghiodi.
"The focus should be improving care for all Medicare patients, not creating yearly physician winners and losers with payment affected two years after care has been delivered."
Perhaps the most often-recurring theme is summed up by Ghiodi's first suggestion: "Keep it simple."
CHIME Chimes In
The College of Healthcare Information Management Executives (CHIME) also urged CMS to simplify the MACRA rules as proposed.
In particular, CHIME suggested that requirements for providers to attest that they are being compliant to exchange information in standard ways with each other be relaxed until such standards are more clearly defined.
"Because the work underway at the Office of the National Coordinator for Health IT (ONC) to tackle these challenges is not yet complete, CMS is inadvertently asking providers to attest to more than they reasonably can at this time," CHIME stated. "The attestations in the final rule should be modified to recognize this."
CHIME also expressed concern that hospitals and clinicians "are on separate trajectories for pathways to achieve meaningful use… the pass/fail construct and full-year reporting period... [do] not advance interoperability enough to achieve the goals of a value-based delivery system."
Consumer Advocates React
A coalition of consumer groups applauded the proposed rule. The Consumer Partnership for eHealth, representing consumer, patient and labor organizations, did recommend changing the single-patient requirement for e-prescribing, patient electric access and secure messaging, to 5% of all patients in 2019.
Premier, a healthcare performance improvement alliance of approximately 3,600 U.S. hospitals and 120,000 other providers, proposed modifications related to APMs, including adding Comprehensive Care for Joint Replacement and Bundled Payment for Care Improvement as Advanced APMs.
By statute, the final rule for MACRA must be issued no later than November 1.