TMA on Monday sent a 27-page 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 also aimed to simplify and improve Medicare's costly and complex programs — such as PQRS, meaningful use, and value-based purchasing -— 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 more details on MACRA, see the TMA website. For additional information on TMA's perspective on the draft rule, read Dr. Read's post on the KevinMD blog.
Action, July 1, 2016
Last Updated On
August 04, 2016