Dear Chairman Walden and Ranking Member Pallone:
The undersigned state and national specialty medical organizations share a common interest in ensuring
successful implementation of the Medicare Access and CHIP Reauthorization Act (MACRA). Since the
enactment of MACRA, we have worked closely with policymakers and the Centers for Medicare &
Medicaid Services (CMS) to ensure that implementation of the law reflects the intent of Congress to focus
payment on improving quality and value and that physician practices are able to successfully participate.
Thanks to statutory provisions designed to provide necessary flexibility during implementation, CMS has
been able to ensure that practices can participate from the outset and increase their engagement over time
as physicians and other clinicians become more accustomed to the new reporting requirements and CMS
finalizes cost measures, improves data feedback, and provides tools to improve performance and help
providers succeed. In order to continue the progress made to date, we believe that there are several
specific adjustments that will require statutory changes or clarification before CMS is required to publish
proposed rules for the program’s third year of operation.
Several provisions of MACRA have been particularly helpful in ensuring successful implementation thus
far. The first, at 1848(q)(5)(E) has allowed CMS to proceed with implementation despite the fact that
resource use (cost) measures necessary under the Merit-based Incentive Payment System (MIPS) are still
under development. This provision allows the Secretary, for the first two years of the MIPS program, to
weight the resource use component at not more than ten percent for the first year and not more than 15
percent for the second year. Given the state of readiness of resource use measures, CMS used this
flexibility in the final rule for 2017 and weighted this component at zero percent. For 2018, CMS has
again proposed to weight this component at zero percent. This action in no way is meant to diminish the
commitment of CMS or the physician community to incorporating resource use as an integral component
of performance measurement. It is instead an acknowledgement that work remains to be done to ensure
that these new measures are developed and integrated in a way that accurately reflects the complexities of
cost measurement and does not inadvertently discourage clinicians from caring for high-risk and
medically complex patients, as was the case under the value-based modifier.
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