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July 2016
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  • Physician Concerns About MACRA Must Be Addressed Before Final Rule is Released

    ISMS advocates for changes to MACRA

    The Centers for Medicare and Medicaid Services (CMS) recently released a proposed rule to implement key provisions of the Medicare Access and CHIP Reauthorization Act (MACRA). This legislation, which became law in April 2015, repealed the flawed sustainable growth rate (SGR) formula and replaced it with other payment options.

    Numerous practices responded to ISMS’ recent request for feedback, which greatly assisted us in communicating our concerns to CMS regarding the MACRA proposed rule. Below are the key points we raised with CMS:

    • ISMS is extremely concerned about the proposed start date of Jan. 1, 2017, for beginning Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) data collection. This start date does not allow sufficient time for practices to prepare to meet the new requirements.
    • Additional steps must be taken to ensure that solo practitioners, small practices and rural practices are not disadvantaged under the new payment system.
    • Additional work is needed to implement MIPS in a way that reduces the administrative burdens and complexities of the program. The proposed requirements for advanced APMs are too restrictive. The final rule should establish timelines and criteria that will allow for existing APMs to be modified and new APMs to be created so that there are appropriate and financially viable options for a wider range of physicians.
    • We encourage CMS to prioritize individual physician education during the MACRA implementation process.

    While ISMS recognizes that CMS has attempted to carefully consider physician feedback and input in developing the proposed rule for MACRA, these concerns must be addressed before the final rule is released.

    ISMS also joined other state and national medical associations in a lengthy letter to CMS’ Acting Administrator Andrew Slavitt, detailing our concerns that certain provisions of MACRA’s proposed rule require considerable modifications.

    Questions? Call your ISMS Advocacy Team at 800-782-4767 ext. 1470 or send an email.

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