June 27, 2016
“Make
a new plan, Stan:” TMA offers 50 ways to improve MACRA.
The Texas Medical Association (TMA) today sent a lengthy
formal comment letter to the Centers for Medicare & Medicaid
Services (CMS) listing TMA’s 50 recommendations to improve the agency’s draft
rule implementing the Medicare
Access and CHIP Reauthorization Act (MACRA).
When
Congress passed MACRA last year to replace Medicare’s Sustainable Growth Rate
(SGR) formula, lawmakers aimed to simplify and improve Medicare’s costly and
complex programs that purport to measure the quality of care physicians provide
to patients.
TMA
says MACRA has fallen far short of that goal.
“If implemented as written, the regulations
would dump additional bureaucratic work on physicians and their practices, and
would continue to impose onerous federal controls on them — with no data to
show that they would improve the quality of or access-to-care for patients,”
said TMA President Don R. Read, MD. “The system devised by CMS is far more
costly, complex, and confusing than the costly, complex, and confusing programs
it is replacing.”
The most critical of TMA’s 50 recommendations
are these three:
- Significantly Expand the Low-Volume Threshold:
According to TMA analysis, physicians who bill less than $250,000 in Medicare
charges will spend more trying to comply with the MACRA rule than they could
ever earn in bonuses — if they hit
the hidden quality targets. CMS set the threshold at a paltry $10,000 in
Medicare allowed charges. TMA told CMS to set the low-volume threshold at
$250,000. That would exempt physicians who have no possibility of a positive
return on their investment in the cost of reporting. For physicians with less
than $250,000 of Medicare revenue, reporting should be optional, and physicians
who attempt compliance should be exempt from any payment penalties.
- Delay the Start: The
rule will be finalized around Nov. 1. Practices will have to begin collecting
data and making big changes in their operations on Jan. 1. This gives
physicians only two months to prepare and they won’t be ready. Support staff
won’t be ready. Electronic health record vendors won’t be ready. TMA told CMS
the measurement period for 2017 should be reduced to six months and start no
sooner than July 1. (The data collected in 2017 affects physicians’ Medicare
payments in 2019.)
- Set the Performance Threshold Low: The
“performance threshold” is the most important factor affecting MACRA’s overall
impact on small practices. CMS has complete discretion to set the performance
threshold, which is the score a physician must earn to avoid penalties. The
threshold also will determine how much MACRA will shift Medicare payments from
smaller physician practices to larger groups and health care systems. To reduce
the negative impact on small practices, TMA urged CMS to set the performance
threshold at 15 percent in the first year of implementation.
For additional information on TMA’s perspective on the
draft rule, read Dr. Read’s post on the
KevinMD blog.
TMA is the largest state medical society in the nation,
representing more than 49,000 physician and medical student members. It is
located in Austin and has 110 component county medical societies around the
state. TMA’s key objective since 1853 is to improve the health of all Texans.
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Contact: Brent Annear (512) 370-1381; cell: (512) 656-7320; email: brent.annear@texmed.org
Marcus Cooper (512)
370-1382; cell: (512) 650-5336; email: marcus.cooper@texmed.org
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