Comments Submitted on MACRA

MACRAquestions-200On April 27, CMS released a notice of proposed rulemaking (NPRM) for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Supported by a bipartisan majority and stakeholders, such as patient and medical associations, the MACRA legislation ended more than a decade of last-minute fixes and potential payment cliffs for Medicare doctors and clinicians. It also made numerous improvements to America’s health care system. Here are the facts from CMS.

The comment period closed on June 27, 2016. You can review comments on Regulations.gov.  Here are selected comments submitted from industry groups.

WEDI issues recommendations to CMS on Proposed Rule for MACRA and MIPS.  The Comment Letter was developed by the Payment Model Workgroup of WEDI in response to the April 27 proposed rule for MIPS and APM incentives, implementing the Medicare Access and CHIP Reauthorization Act (MACRA). The goal of these comments is to constructively engage with CMS to improve the implementation and sustainability of the MACRA-related activity by the industry.

The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the proposed rule entitled, “Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive under the Physician Fee Schedule (PFS), and Criteria for Physician-Focused Payment Models; Proposed Rule” released on May 9, 2016 with file code CMS-5517-P. We look forward to continuing to work with the Centers for Medicare & Medicaid Services (CMS) on implementing MIPS and APMs successfully.

Consumer Partnership for eHealth – Proposed MACRA Rule is ‘Encouraging First Step in Driving the Health Care System Transformation Our Country Needs,’ Consumer Advocate Says. In comments submitted to the Centers for Medicare & Medicaid Services, the National Partnership for Women & Families praised the proposed Medicare Access and CHIP Reauthorization Act (MACRA) rule for its potential to strengthen the delivery of health care for Medicare beneficiaries and promote high-value care.

HIMSS EHRA – Established in 2004, the Electronic Health Record (EHR) Association is comprised of over 30 companies that supply the vast majority of EHRs to physicians’ practices and hospitals across the US. These comments are based on the collective perspectives and experiences of more than 30 Association member companies who serve the majority of hospitals and ambulatory care providers using EHRs across the US.

On behalf of the Electronic Health Record (EHR) Association, they submitted the following comments on the Centers for Medicare and Medicaid Services Notice of Proposed Rulemaking (NPRM) on the Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models. These comments are based on the collective perspectives and experiences of more than 30 Association member companies who serve the majority of hospitals and ambulatory care providers using EHRs across the US.

The Utilization Review Accreditation Commission (URAC) submitted comments to CMS about how the government might improve its proposed rule to implement health care reimbursements as authorized by the Medicare Access and CHIP Reauthorization Act (MACRA). “We believe that flexibility, sustainability, and quality improvement are not mutually exclusive ideas,” said URAC President and CEO Kylanne Green. “URAC believes that CMS could further promote and more effectively measure quality over time through the creation of a minimal framework that highlights the alignment of Clinical Practice Improvement Activities with the PCMH model for physicians.”