Dear Acting Administrator Slavitt:
With the upcoming release of the proposed rule regarding implementation of the Medicare
Access and CHIP Reauthorization Act (MACRA), we are writing to ensure that activities in the
private sector continue, and have a defined pathway to meet the Alternative Payment Model
(APM) criteria. The undersigned organizations reflect a wide breadth of companies and
organizations that share your commitment to a strong Medicare payment system that better
meets the healthcare needs of its beneficiaries through the adoption of a framework that
rewards clinicians for value over volume, and streamlines other existing quality reporting
programs into one new system.
Our collective goal is to ensure the implementation of MACRA does not create an overly
prescriptive, time-consuming and complex federal approval process for clinical quality
improvement and APMs as this could undermine existing programs that are already
extraordinarily effective in improving care and containing costs. While each undersigned
organization has unique perspectives and concerns regarding the rollout of MACRA, there are
overarching topics on which we are unanimous and urge CMS to strongly consider adopting the
following recommendations when developing policies for both the MIPS and APM tracks:
First, it is important the implementation of MACRA does not disrupt the positive effect
APMs are having on beneficiaries’ health in both the public and private sectors. As you
know, APMs such as Patient-Centered Medical Homes (PCMHs) and Accountable Care
Organizations (ACOs) have shown great promise and proven potential in improving quality while
maintaining or reducing costs to the healthcare system. There are diverse approaches being
taken by physicians, private payers, and CMMI that have demonstrated that there is no one way
to achieve the shared goals of building a health care delivery system that is better, smarter and
healthier. CMS should allow for maximum flexibility on the public and private sector sides and
not inadvertently create rules around participation that have a chilling effect on the ability to
innovate—for both physicians and payers. Maximum flexibility would help enable both private
sector and public sector APMs to work in concert, as opposed to the potential for confusion or
conflicting requirements. Ensuring a broad variety of APMs that suit local markets and the
diversity of physician practice – including both primary care and other specialties — is essential
to achieving the goals of this program.
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