The American College of Cardiology (ACC) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on June 27 regarding the proposed Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) regulations.
ACC President Richard A. Chazal, MD, detailed the organization’s remarks in a 35-page letter addressed to acting CMS administrator Andrew Slavitt.
The Senate and House of Representatives last spring passed MACRA, which repealed the sustainable growth rate formula and focused on tying physicians’ reimbursement to value-based care.
CMS is expected to release the final MACRA regulation by November 1. The rules will be in effect starting Jan. 1, 2017.
The ACC’s letter requested that CMS simplify the quality payment program and work with clinicians and practice administrators to understand the reporting requirements. The organization said that it was concerned with group-level reporting under the Merit-Based Incentive Payment System (MIPS) and several Advanced Alternative Payment Models (APMs). The MIPS and APMs are expected to be in place in 2019.
The ACC also asked CMS to refine the low volume MIP exemption threshold and the non-patient facing clinician definition. In addition, the organization said it opposed the proposal to increase the successful reporting threshold from 50 percent to 80 percent or 90 percent of all applicable patients.
“The Quality Payment Program under MACRA aligns with the ACC’s own strategic vision to transform the delivery of care and encourage clinicians to provide high-quality patient care,” Chazal wrote. “The College is working diligently to understand the new requirements of the MIPS and Advanced APM pathways so that our membership can be prepared for the changes and understand their responsibilities under the new payment system. The College cannot emphasize enough how important it will be that CMS provide transparent education to clinicians and practice administrators to minimize the potential burden of these new policies. The ACC and other medical specialty societies are eager to assist the agency in outreach efforts.”