Dear Acting Administrator Slavitt and Director Donovan:
On April 27th, CMS released a proposed rule to implement the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. By repealing the Sustainable Growth Rate Formula, MACRA has the potential to transform the healthcare landscape and the delivery of care. However, if CMS implements the rule in a manner which is inconsistent with Congressional intent, MACRA has the potential to overcomplicate an already burdensome and complex quality reporting system and take more time away from patient care.
According to a Health Affairs study published in March of 2016, physician practices in four common specialties spend, on average, 785 hours per physician and more than $15.4 billion each year on quality measure reporting programs. Furthermore, the majority of time spend on quality reporting consists of “entering information in the medical record only for the purpose of reporting quality measures from external entities,” and nearly three-quarters of practices stated their group was being evaluated on quality measures that were not clinically relevant. Congress recognized that these programs may actually detract from quality care by driving providers’ time away from patients, and, as a result, replaces them with what is supposed to be a streamlined quality program, known as the Merit-based Incentive Payment System (MIPS).
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