The American Medical Association (AMA) and the American Hospital Association (AHA) appear pleased with the proposed rule for the second year of the Quality Payment Program (QPP), with some groups reserving judgment until they have time to review the 1,058-page regulation.
With CMS now under the leadership of Seema Verma, MPH, and HHS Secretary Tom Price, MD, the proposed rule seems to reflect their own criticisms of the Medicare Access and CHIP Reauthorization Act (MACRA) payment tracks—namely, that they were too challenging for small, rural practices. The proposed rule addresses those complaints by raising the low-volume exemption threshold for the Merit-based Incentive Payment System (MIPS). This could potentially exempt hundreds of thousands of additional Medicare clinicians from the program, even though 65 percent were already exempted in 2017.
“That leaves hardly anyone in MIPS,” tweeted former CMS senior communications strategist Aisling McDonough.
To groups like the AMA, however, the proposed rule illustrates the new administration at CMS shares their concerns and wants to help physicians avoid penalties under the new tracks.
“In proposing these rules, the Administration has taken another step to make sure the promise of MACRA—where physicians are rewarded for improvement and for delivering high-quality, high-value care—will be fulfilled,” said AMA President David Barbe, MD. “Patients and physicians will benefit from the new MACRA approach, as flexibility is vital when implementing a wide-ranging reform. Not all physicians and their practices were ready to make the leap, and many faced daunting challenges. This flexible approach will give physicians more options to participate in MACRA and takes into consideration the diversity of medical practices throughout the country.”
Of particular interest to the AHA was the facility-based clinician reporting option included in the proposed rule. The new scoring mechanism, which would be optional, would be based on the Hospital Value-Based Purchasing Program, and available only for facility-based clinicians “who have at least 75 percent of their covered professional services supplied in the inpatient hospital setting or emergency department.”
One aspect of the proposed rule did concern hospitals: EHR requirements. The proposal would allow physicians to continue using 2014 Edition CEHRT (Certified Electronic Health Record Technology), but under meaningful use requirements, hospitals would still need to have a 2015 CEHRT in place by March 31, 2018 to avoid penalties.
“We will encourage CMS to provide the same relief to hospitals,” said AHA Executive Vice President Tom Nickels.
That same change to CEHRT requirements had been suggested by the American Academy of Family Physicians (AAFP) in a recent letter to Verma about the QPP. Several of the group’s suggestions made it into the proposed rule, such as offering a “virtual group” reporting option
The 60-day comment period for the proposed rule runs until August 21. Other specialty groups said they’ll save their reaction after making a more thorough review. The American College of Radiology, for example, is promising to release a “radiology-specific summary of the rule in the coming days.”