Proposed Rule for Quality Payment Program Year 2
CMS Fact Sheet
The Quality Payment Program, established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), began in 2017, known as the transition year. The Program’s main goals are to:
* Improve health outcomes.
* Spend wisely.
* Minimize burden of participation.
* Be fair and transparent.
The Quality Payment Program has 2 tracks: (1) The Merit-based Incentive Payment System (MIPS) and (2) Advanced Alternative Payment Models (Advanced APMs).
Because the Quality Payment Program brings significant changes to how clinicians are paid within Medicare, the Centers for Medicare & Medicaid Services (CMS) is continuing to go slow and use stakeholder feedback to find ways to streamline and reduce clinician burden, and make it easier for clinicians to participate and put their patients first.
Fact Sheet: Quality Payment Program – 26 pages
Link to provide comment:
Could MACRA Be Key to Fixing Healthcare?
By Gregory A. Freeman
HealthLeaders Media, August 9, 2017
A system that encourages shared savings and shared risk between health plans and providers could address many of the Affordable Care Act’s problems. Health plans are likely to move away from fee-for-service payments to a managed care approach, one analyst says.
The government could be sitting on a solution to the healthcare debate and not even realize it, suggests one analyst. The act that finally fixed a problem threatening to bankrupt physicians every year could show the way to fixing the Affordable Care Act, he says.
The Medicare Access and CHIP Reauthorization Act (MACRA) may provide a roadmap and policy vehicle to address questions of quality, cost, accessibility, says Bruce A. Johnson, JD, a shareholder with the Polsinelli law firm in Denver, CO.
MACRA is based on the idea of shared risk and shared savings, and Johnson says the same theory could be applied to the ACA. Health plans are already moving in that direction, without waiting for the government to lead, he says.
Known as the “doc fix,” MACRA is a recent bi-partisan legislative action that eliminated a nearly 20-year-old problem with how Medicare set payments to physicians. Congress passed the act in 2015 to put an end to an annual drama in which physicians faced huge Medicare pay cuts, 21% that year, if legislators didn’t take emergency measures to stop it for another year.
By fixing the problem, MACRA eliminated substantial uncertainty about the stability of Medicare related to physicians leaving the program because they couldn’t make enough money – similar to how profitability issues have driven health plans out of the state exchanges.
MACRA introduced performance-based reimbursement by rewarding practices that participate in alternative payment models (APMs) such as accountable care organizations (ACOs), and through a merit-based incentive payment system (MIPS).
The first couple of years focused specifically on Medicare-only programs, but then in future years some of the MACRA models include consideration of commercial populations, he notes.
“Health plans are incrementally trying to move toward different forms of shared savings programs and some level of risk for providers. We’re seeing United and the Blues doing some of that, and clearly Medicare Advantage plans are in one way or another willing to have providers take risks through capitation or basically managed care,” Johnson says.
By Don McCanne, M.D.
The comment period for the proposed rule for CMS’s Quality Payment Program closes Monday, August 21. Thus you have this weekend to provide your input, or live with the consequences (comment link here).
To get a quick idea of what this is about, you do not have to read the full 491 pages of the Federal Register where the proposed rule is published, rather you can check the fact sheet provided by CMS (link above). The first three pages describe the CMS Quality Payment Program, MACRA, MIPS, and APMs, and most of the rest of the 26 pages is a table that lists the provisions of the proposed rule. You should skim through that table and, as you do so, ask yourself how this helps patients. (You will not need to ask yourself how this might increase physician burnout because it will be patently obvious.)
CMS Secretary Tom Price has said repeatedly that he would reduce the regulatory burden on physicians. Yet, as a Member of Congress, he was a leader in passing the MACRA legislation. The purpose was to end the flawed SGR formula for physician payment, and to consolidate and expand the quality payment programs. But it is the quality payment programs themselves under MACRA, MIPS and APMs that are so maddening in expanding the useless administrative burden being placed on physicians.
So why has there been such dogged support for this program? The HealthLeaders Media article gives us a clue. Bruce A. Johnson, JD says, “Health plans are incrementally trying to move toward different forms of shared savings programs and some level of risk for providers. We’re seeing United and the Blues doing some of that, and clearly Medicare Advantage plans are in one way or another willing to have providers take risks through capitation or basically managed care.”
THE PRIVATE INSURERS ARE TRANSFERRING RISK TO THE PHYSICIANS. Excuse the shouting, but this point seems to be important. Not only are they dumping more administrative burdens on the physicians, they are trying to dump on them their own responsibility for insuring risk. Talk about an industry that we really do not need in health care today. We are paying them huge sums as they shirk their responsibilities.
If you are interested in providing comment on this rule, the instructions are at the beginning of the proposed rule as published in the Federal Register (link above). But, again, you will have only this weekend to do it since the comment period will close Monday.
After this weekend, we need to get back to the task of throwing out the private insurance industry. At the same time we need to recognize that this is our government that has enacted and is implementing MACRA and the Quality Payment Program. We cannot overemphasize the importance of “Improved” in a single payer Improved Medicare for All. Keep alert.
Stay informed! Visit www.pnhp.org/qotd to sign up for daily email updates.