The AHA May 11 submitted to the House Ways and Means Health Subcommittee several overarching recommendations for the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM) that the Centers for Medicare & Medicaid Services (CMS) will implement in 2019 under the Medicare Access and CHIP Reauthorization Act (MACRA).

In a statement for a subcommittee hearing on implementing the law, the AHA urged the adoption of a MIPS that “measures providers fairly, minimizes unnecessary data collection and reporting burden, focuses on important quality issues and promotes collaboration across the silos of the health care delivery system.”

To achieve this, the association said CMS should focus the MIPS measures on national priority areas; allow hospital-based physicians to use their hospital’s performance on quality reporting and pay-for-performance measures in the MIPS; employ risk adjustment rigorously – including sociodemographic adjustment, where appropriate; and align Electronic Health Record Incentive Program changes for physicians with those for eligible hospitals.

The AHA said the APM incentives should be implemented in a manner that provides the greatest opportunity for physicians to become qualifying participants. The association also urged Congress to adopt a broad exception to fraud and abuse laws that impede collaboration and improvement across the care continuum.

Section 101 of MACRA repeals the Medicare sustainable growth rate methodology for updates to the physician fee schedule and requires CMS to establish new physician quality and value-based payment programs that start in 2019. Eligible clinicians will participate in either the MIPS or APM tracks. CMS April 27 issued a proposed rule implementing key provisions of the new physician payment system. 

An entity that participates in an eligible APM must bear financial risk for any excess Medicare spending over projected expenditures, or be a specified medical home. For 2019 APM incentive payments, eligible models based on financial risk would be Tracks 2 and 3 of the Medicare Shared Savings Program, the Next Generation accountable care organization model, the Comprehensive End-stage Renal Disease Care model, and the two-sided risk model in the Oncology Care program, under CMS’s proposal.

Testifying before the Ways and Means panel, CMS Acting Administrator Andy Slavitt said the new payment system “must be flexible, practice-driven, and patient-centered. It must contain achievable measures; it must support the continued development of health IT infrastructure through interoperability; it must engage and educate physicians and others clinicians; and it must promote and reward improvement over time.”