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 Volume 18, No. 25                 

June 27, 2016            

TMA Has 50 Ways to Fix MACRA

In just a few hours, TMA President Don Read, MD, will submit a 25-page comment letter to the Centers for Medicare & Medicaid Services (CMS) with TMA’s 50 recommendations to fix the agency’s draft rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA). A TMA staff team, working under the direction of the Council on Health Care Quality and Council on Socioeconomics, has spent nearly two months studying the draft rule. As I’ve explained previously, the draft would create a system that’s far too costly and complicated for physicians to use. It brings no real promise of improved patient care, and it’s not what Congress ordered. The most critical of our 50 recommendations are these three: 

  • Significantly Expand the Low-Volume Threshold: According to our 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. We are telling 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. Two months. That’s ridiculous. Physicians won’t be ready. Support staff won’t be ready. Electronic health record vendors won’t be read. We are telling CMS the measurement period for 2017 should be reduced to six months and start no sooner than July 1. (Remember, the data collected in 2017 affect your 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, we are urging CMS to set the performance threshold at 15 percent in the first year of implementation. 

Today Is Your Last Chance to Tell Feds What to Do With MACRA

Monday, June 27, 2016, at 10:59 pm, Central Time — that’s tonight, one minute before 11 pm, and that’s the very last moment you can send your comments on the MACRA rule to CMS. Because you’re a TMA leader, I’m sure you’ve sent one of the 570 comments that have flowed so far through our Grassroots Action Center to CMS. But just in case you haven’t yet, please do it now. We need to make sure Washington hears exactly what Texas is thinking. As Dr. Read wrote in an email to all TMA members, “As physicians, we must stand up to this incredible bullying from the federal government. For your patients, your practice, and our profession, please take action today. When we speak out with one voice, we can make a difference.” Please do it today — before 11 pm.

Coalition Asks for Small Practice Exemption From MACRA

Most members of the 10-state Coalition of State Medical Societies are submitting their own, individual MACRA comments to the Medicare agency. One point was so important to all of us, however, that we decided to issue a short but powerful statement in support of solo practitioners and physicians who practice in small groups. “We want to focus your attention on the devastating impact the proposed rules would have on solo practitioners, small practices, and physicians serving patients in health care professional shortage areas (HPSAs), all of whom have limited resources,” the coalition wrote in a joint comment letter to be submitted today. “Because the cost of reporting is so high for small practices — and because of the real threat of penalties or inadequate bonus payments that do not cover the costs to report — few small practices can participate. The proposed [$10,000] low-volume threshold is not a meaningful exemption for small and rural practices. … We strongly urge CMS to exempt those physicians who have no possibility of earning more than it costs them to report.” The coalition — comprising the state medical societies in Arizona, California, Florida, Louisiana, Oklahoma, New Jersey, New York, North Carolina, South Carolina, and Texas — represents more than 180,000 U.S. physicians and medical students.