As 2017 approaches, it’s time for you to begin preparing for the Medicare Access and CHIP Reauthorization Act (MACRA). While the final rule was already issued by the Centers for Medicare and Medicaid Services (CMS), at CMS’ request the Advocacy Council recently submitted comments and recommendations on your behalf. Comments addressed aspects of the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APM) rules. Highlights include:
- We asked for a low volume exception that would be applied to small group practices if either:
a) The average Medicare charges for clinicians in the group are below the low-volume dollar or patient threshold, OR
b) At least 75% of the group’s clinicians are below the threshold.
- We expressed concern for clinicians who would qualify for the exception if they reported as individuals, but who do not qualify when reporting as part of a group. This may include physicians working less than full-time (could disproportionately impact women), physicians moving toward retirement and physicians with disabilities working a reduced schedule.
- We urged an extension of the transition timeline through 2018, noting physicians in small practices may not be ready for full participation by the beginning of 2018.
MIPS cost category
- We asked for proper testing before the cost category is included in MIPS scoring to avoid patient attribution errors.
MIPS quality measures
- We asked for a reduction in reportable quality measures until such time as specialty specific appropriate measures have been established.
Advanced APM approval process
- We asked that the process for submitting APM’s be clarified and streamlined and called for increasing transparency from the Physician-focused Payment Model Technical Advisory Committee and CMS.
While our submission is fairly recent and we have not received a response from CMS, it’s important for you to know the College and Advocacy Council take every opportunity to represent the practicing allergists – we’ve got you covered! Stay tuned for updates.