The AHA earlier this week called on the Centers for Medicare & Medicaid Services (CMS) to expand its proposed definition of advanced alternative payment models (APM) for the physician quality payment program.
The AHA weighed in on the agency’s April 27 proposed rule implementing key provisions of the new physician payment system created under the 2015 Medicare Access and CHIP Reauthorization Act (MACRA).
MACRA consolidates a patchwork of programs into two paths for physicians receiving Medicare payments: the Merit-based Incentive Payment Systems (MIPS) and advanced APMs. The agency received nearly 4,000 comments on the proposed rule, with most critical of the regulations.
In its June 27 letter to CMS, the AHA expressed disappointment that few of the models in which hospitals have engaged would qualify as advanced APMs, and urged the agency to adopt a “more inclusive approach.”
CMS should expand its definition of financial risk to “include the investment risk borne by providers who participate in APMs, and to develop a method to capture and quantify such risk,” wrote AHA Executive Vice President Tom Nickels. “We also urge the agency to update existing models, such as the Bundled Payments for Care Initiative and the [Comprehensive Care for Joint Replacement Initiative], so that those models would qualify as advanced APMs.”
The AHA faulted CMS’s proposed approach for failing 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."
Among other changes, the AHA urged that MIPS allow hospital-based physicians to use their hospital’s performance on CMS hospital quality reporting and pay-for-performance programs; incorporate socioeconomic adjustment; and align its advancing care information performance category with the hospital meaningful use program.
The AHA also supported a number of the rule’s proposed flexibilities, and urged the agency to monitor the field’s readiness and consider additional flexibility in the timeline and other requirements.
For example, the AHA suggested reducing the reporting period under the Advancing Care Information (ACI) category. CMS said ACI would replace meaningful use in efforts to realign Medicare payments with patient-centered, quality care. It is designed to provide more flexibility for physicians when it comes to reporting quality care and certified electronic health record (HER) use.
“The proposed rule includes a full calendar year of reporting for the ACI category,” the AHA wrote. “The AHA recommends that CMS finalize a shorter, 90-day reporting period for the ACI category and for any provisions in the final rule where an eligible clinician would use a certified EHR to meet a program requirement.”