As the Centers for Medicare & Medicaid Services (CMS) prepares to implement new delivery and payment models and a streamlined incentive program, physicians took the lead in outlining principles that should govern these Medicare reforms.
More than 100 state and specialty medical associations joined the AMA in signing a letter sent Monday to the Centers for Medicare & Medicaid Services (CMS) that recommends 10 principles to guide the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA), the Medicare reform law that repealed the sustainable growth rate formula.
In particular, the recommendations deal with alternative payment models (APM) and the Merit-Based Incentive Payment System (MIPS), which are intended to promote improvements in the delivery of care for Medicare patients. They are:
- Support delivery system improvements. Constraints and limitations of current payment systems that obstruct physician-identified improvements in care must be eliminated. Requirements for new models should be flexible enough to support different organizational arrangements and patient population needs so innovation can flourish.
- Avoid administrative and cost burdens for patients. Patients should not be unduly burdened with hidden costs, administrative requirements or other obstacles that discourage them from seeking care or fulfilling their treatment plans.
- Reduce administrative burdens for physicians. Administrative burdens must be limited and reporting tasks streamlined so the delivery of patient-centered care can be the principal focus in all clinical settings.
- Improve current quality and reporting systems. Medicare’s existing reporting and quality measurement programs cannot simply be combined to create the new MIPS. These currently separate programs must be carefully assessed, revised, aligned and streamlined into a coherent and flexible system that is truly relevant to high-value care. The regulatory framework of the meaningful use program for electronic health records must be revised to eliminate obstacles to technological innovation, enable interoperability, and improve usability to meet the needs of patient care and reduce the burden of excessive data collection requirements.
- Recognize patient diversity. Risk adjustment—for factors related to health status, stage of disease, genetic factors, local demographics and socioeconomic status—must be reflected in performance assessments to accommodate variations in patient needs and costs of care and to assure broad access to high-value care.
- Provide choice of payment models. Physicians in all specialties, practice settings and geographic areas should have the opportunity to choose from the payment models available, based on what best accommodates their practice and the needs of their patients.
- Be equitable. No specialty or payment model should confront disproportionate requirements in order to succeed, nor should any specialty experience hardship because insufficient resources have been devoted to developing quality measures or other delivery model components that are relevant to their patients.
- Be relevant and actionable. Physicians should be held accountable only for those aspects of cost and quality that they can reasonably influence or control, and patient attribution methods must reflect these concerns. Timelines and deadlines must be realistic, significant policy changes should be phased in, and feedback on individual performance and benchmarks must be accurate, timely and actionable.
- Provide stability and resources. Payment systems must provide adequate and predictable resources, and ensure that physicians have access to new tools they will need to redesign their practices to support the delivery of high-value care to all patients.
- Be transparent. Methodologies and performance assessment systems should be valid, scientifically tested and transparent so physicians have access to timely, accurate and actionable data for managing patient care.
Medicare must provide claims and other performance data to physicians on the patient population covered by the delivery and payment model used in their practice.
The letter also noted that these principles are just the start. An ongoing dialogue with the physician community “will promote smooth and successful implementation of MIPS and APMs,” and help physicians make the transition to new care and delivery models while assuring access to high-quality care for all patients, the letter said.
The AMA also submitted detailed comments to CMS this week, responding to questions in a request for information on MACRA implementation.
Learn more about MACRA and new payment models
- Interested in learning more about MACRA? An AMA Wire® series takes a look at the law’s main elements, including its support for new payment models.
- As part of its Professional Satisfaction and Practice Sustainability initiative, the AMA offers two resources to help physicians with contracting under an alternative payment model.
- The AMA and the RAND Corporation recently conducted case studies of 34 physician practices in six diverse geographic markets to determine the effects that alternative health care payment models had on physicians and practices.
- AMA President Steven J. Stack, MD, has detailed the root of new payment model challenges. He writes about how physicians need better data and tools and ways the AMA is ensuring they are on the ground floor of the development of these tools.