MACRA: Stakeholders Considerations and Next Steps
Briefing Presented by Alliance for Health Reform with Support from BCBSA and AMA – July 11th, 2016
On Monday, stakeholders representing insurance (Donald Fisher from Highmark), patient-advocacy (Stephanie Glover from National Partnership for Women & Families), hospital and clinic systems (Tonya Wells from Trinity Health), government (Lemenah Tefera from CMS), and provider (Thomas Eppes from Central Virginia Family Physicians) interests gathered at Dirksen Senate Building for panel presentation and a subsequent Q & A period. The majority of the attention was directed at Tefera, who presented largely informational material on the structure of the Quality Payment Program (QPP) created under MACRA, with a particular focus on practical and functional considerations of the Merit-Based Incentive Payment System (MIPS), which he stressed that the vast majority of physicians will be subject to.
Fisher, Wells, and Eppes all recommended a delayed timeline for the implementation of the two tracks of the QPP – MIPS and Advanced Alternative Payment Models (Advanced APMs). Specifically, Eppes called for a July 2017 start date for the performance period for both MIPS and Advanced APMs, particularly looking to the chance for more APMs to be qualified as MIPS or Advanced APMs at the beginning of the performance period. Wells went further, recommending January 1, 2018 as the performance year start date for both MIPS and Advanced APMs, making 2020 the first payment year. Fisher spoke of a general MIPS “soft-launch” with education and outreach, staggered start dates for the various MIPS categories, and modified benchmarks for evaluation (to be regional or specialty-specific), in addition to a delayed start date for the performance period. Tefera responded by depending the performance period as a window for reporting rather than a deadline, increasing the possibility for greater reporting flexibility.
In line with their advice to delay the implementation timeline, Fisher, Wells, and Eppes stressed that they did not want to undo the progress away from fee-for-service (FFS) to paying for value that has been made by models such as Track 1 ACOs, BPCI, and CJR – all of which do not currently qualify as Advanced APMs – and hope to see reduced requirements and/or a clear path that will allow such models to mature into Advanced APMs. Eppes in particular predicted physician drop out – moving to exclusively seeing patients with private insurance, concierge medicine arrangements, and other options – if the QPP retains its current form. Tefera largely deferred to lawmakers on the Hill in his response that such guidelines determining qualification for Advanced APMs are set and required by the statute as written, leaving CMS with no power to modify them.
Glover representing patient advocacy efforts took a different stance than the other panelists, calling for more strident standards. In particular, she spoke to the addition of patient and family engagement – even beyond the point of care — in the clinical improvement activities for MIPS evaluation, robust use of health IT to advance the ability of patients to interact with their health information, and the inclusion of quality measures derived from patient-generated data that address care experience and outcomes.
Ultimately, all applauded CMS’ work with MACRA to eliminate the sustainable growth rate (SGR) and further the transition from FFS to paying for value. Their recommendations surrounded how to best address implementation concerns that could thwart such a transition.