Dear Administrator Verma:
The undersigned physician organizations welcome the Trump Administration’s emphasis on
reducing regulatory burdens. Congress recognized when it passed the Medicare Access and
CHIP Reauthorization Act (MACRA) in an overwhelming bipartisan vote that the existing
Medicare value-based purchasing programs affecting physicians—Meaningful Use (MU),
Physician Quality Reporting System (PQRS), and Value-based payment modifier (VM–needed
to be streamlined and aligned. As the Centers for Medicare & Medicaid Services (CMS)
implemented MACRA through the Quality Payment Program (QPP), we were grateful the
agency recognized there were a number of challenges with the requirements of MU, PQRS, and
VM. Consequently, we urge the Administration to take a series of steps to address these same
challenges in MU, PQRS, and VM prior to their replacement by MACRA and minimize the
penalties assessed for physicians who tried to participate in these programs. Clearly this would
send a strong message to the physician community about the extensive regulations with which
physicians have been dealing and the Administration’s commitment to reduce the burden.
As directed by the 21st Century Cures Act, CMS must establish a strategy to relieve the
electronic health record (EHR) documentation burden. To fulfill this legislative directive, we
urge CMS to establish a new “Administrative Burden” category of hardship exemption for the
2016 MU performance year. Eligible providers should not be penalized for focusing on
providing quality patient care rather than the arbitrary “check the box” requirements of MU.
Creating an administrative burden hardship exemption would provide immediate relief for those
impacted by the programs that predate MACRA.
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