Statement of the Alliance of Specialty Medicine on MACRA Implementation
before the
Subcommittee on Health of the Committee on Energy and Commerce
of the U.S. House of Representatives
Tuesday, April 19, 2016
The Alliance of Specialty Medicine (Alliance) is a coalition of national medical specialty societies
representing more than 100,000 physicians and surgeons. We are dedicated to the development of sound
health care policies that foster patient access to the highest quality specialty care. The Alliance appreciates
that Congress devoted a portion of the Medicare Access and CHIP Reauthorization Act (MACRA), P.L. 114-
10, to streamlining existing federal quality reporting mandates, addressing obstacles that currently prevent
specialists from participating meaningfully in these programs and reducing the amount of physician payment
at risk. We also appreciate that MACRA affords specialty societies the opportunity to work closely with
CMS to determine how best to interpret the law.
In preparation for MACRA implementation, Alliance societies have been educating their members about the
Merit-Based Incentive Payment System (MIPS) and participation in Alternative Payment Models (APMs)
and gathering feedback on the most pressing policy and operational implications for specialty medicine. We
look forward to sharing additional insights with Congress and the Centers for Medicare & Medicaid Services
(CMS) as we continue to collect this information. In the interim, we would like to share specialty medicine’s
overarching recommendations and most pressing concerns.
Our specific principles and concerns about MIPS and APMs are outlined below:
Merit-based Incentive Payment System (MIPS)
- Gradual, thoughtful implementation will be the key to success. The Physician Quality
Reporting System (PQRS), the Electronic Health Record (EHR) Incentive Program and the ValueBased Payment Modifier (VM) were all well-intentioned programs but implemented via strategies
that were flawed on many levels. As a result, these programs were unnecessarily burdensome and
produced largely meaningless data. There is a real fear that policymakers will maintain the flawed
features of these programs and simply combine them under a dysfunctional system that differs in
name only. Version 1.0 of MIPS cannot simply become Version 2.0 of the PQRS, EHR Incentive
Program and the VM. MIPS represents a critical opportunity to press the reset button on current
programs — to take a careful inventory of what is and what is not working for both patients and
physicians, and to use those experiences to correct things that might not have been carried out
appropriately in the past. However, building a new quality infrastructure will require a thoughtful and
gradual approach to ensure that the initial transition to this new system is as seamless and
undisruptive to clinical practice as possible. This will include balancing the need to maintain certain
elements of current programs that physicians find suitable and are familiar with while abandoning
the most critically flawed features and testing alternative strategies that allow physicians to
demonstrate value in more innovative ways. To date, CMS has done little to evaluate whether
existing federal mandates have had a meaningful effect on quality improvement across physician
specialties. - Flexibility will ensure meaningful engagement. When developing MIPS policies, it is critical that
CMS take a flexible, rather than prescriptive, one-size-fits-all approach. Ensuring that MIPS is
2
relevant to all specialties will help to not only ease the transition to this new system but will also
foster innovation, trust and ultimately widespread stakeholder engagement. - Investment in measure gaps must occur expeditiously. For many specialties, the most
significant barrier to meaningful participation in current programs is an ongoing lack of relevant
measures. CMS must expeditiously support — through financial investments, technical assistance,
and greater access to data — the development of high-quality, specialty-focused measures to
ensure that all physicians have a fair opportunity to demonstrate quality and value for the unique
conditions and populations they treat. The paucity of relevant resource use measures is especially
critical. Few, if any, specialties have been able to identify resource use measures suitable for
accountability. Cost profiles are difficult to create for the individual provider, requiring the
development of complex risk adjustments and attribution methodologies and open access to allpayer data. While CMS and its contractors have been working for many years to develop more
granular episode-based resource use measures, they are not expected to be ready in time for the
initial performance year of MIPS. As a result, CMS will need to adopt a contingency plan that
reflects the current state of measurement. To ensure that physicians are not inappropriately
penalized, this plan should include a re-weighting of the resource use category of MIPS until these
challenges are resolved. It is equally critical that CMS retire the current flawed resource use
measures used under the VM, which were not developed with physician input and hold specialists
accountable for care provided outside of their control, and if necessary, consider surrogate metrics
in the interim, such as those that evaluate appropriate use. In general, resource use measures
should not have an adverse impact on practice patterns or discourage treatments that best meet the
needs of individual patients. For example, CMS’ current resource use methodology is constructed in
a way that disincentivizes the use of Part B drugs over Part D drugs, which can interfere with
treatment decisions and patient preferences.
…
Read full article here
