The Honorable Greg Murphy, MD, Co-Chair Republican Doctors Caucus
The Honorable John Joyce, MD, Co-Chair Republican Doctors Caucus
The Honorable Kim Schrier, MD, Chair, Democratic Doctors Caucus
U.S. House of Representatives
Washington, DC 20515

RE: Feedback on MACRA Discussion Draft

Dear Chairs Murphy, Joyce, and Schrier:

The undersigned members of the Alliance of Specialty Medicine (Alliance) thank you for your leadership and welcome the opportunity to comment on your April 23 Discussion Draft to modernize the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The Alliance, which represents 15 specialty organizations and more than 100,000 physicians, is dedicated to the development of sound federal health care policy that fosters patient access to the highest quality specialty care. The Alliance greatly appreciates your proactive engagement and willingness to collaborate with us and other stakeholders.

For your convenience, we have organized our comments to follow the Titles and Sections of your discussion draft.
We would be happy to meet with you to discuss it in greater detail.

TITLE I—STRENGTHENING REIMBURSEMENT AND PATIENT ACCESS

SEC. 101. MODIFYING THE CONVERSION FACTOR UPDATES APPLICABLE TO PHYSICIANS’ SERVICES UNDER THE
MEDICARE PROGRAM. (pp. 2-3)

We appreciate that the discussion draft would incorporate a Medicare Economic Index (MEI)-based update into the Medicare physician fee schedule (PFS), however, applying adjustments or caps to that update falls short of ensuring that physician payment reflects the full cost of providing care. As we have emphasized in prior comments, Medicare physician payment must include an annual, predictable update tied to the full MEI to account for inflation in practice costs. We, therefore, support the provisions in H.R. 6160, Strengthening Medicare for Patients and Providers Act, which would provide a permanent, inflation-based update equal to 100 percent of the MEI, without reductions or caps. A full MEI update is essential to promote long-term stability in the Medicare physician payment system and help ensure continued patient access to specialty medical care.

Click here to view the full Alliance of Specialty Medicine Feedback on MACRA Discussion