The deadline to submit comments on the sweeping payment and delivery changes proposed by the Medicare Access and CHIP Reauthorization Act to the Centers for Medicare & Medicaid Services was June 27. Most major health organization have made their voices heard.

In letter sent Monday to acting CMS administrator Andy Slavitt, HIMSS lauded the agency for its "transparent and inclusive" efforts to gather industry feedback, and thanked CMS for its attempts to "minimize the administrative burden on organizations and clinicians."

But it also made clear that the "flexibility" promised by CMS to physicians participating in MACRA's two main tracks, the Merit Based Incentive Payment System and Alternative Payment Models, may not be as obvious as it appears.

"In creating this flexibility, CMS is proposing a level of complexity that increases the burden on eligible clinicians," HIMSS wrote.

Moreover, the timeline for the new framework's rollout – with a final rule and kick-off for the first reporting period both set for Jan. 1, 2017 – is extremely tight. As such, HIMSS has asked CMS change the reporting period for the Advancing Care Information component of MIPS (which would essentially replace meaningful use for Medicare physicians) to 90 days. 

More broadly, HIMSS wants CMS to "redouble its efforts" to ensure clinicians are better educated about MACRA requirements, and that the small practices are not too burdened with bureaucratic hoop-jumping.

With regard to the technology-focused Advancing Care Information requirements, HIMSS insisted that the "requirements are not overly burdensome" to eligible clinicians. CMS should ease the complexity of quality reporting," since "health IT reduces the need to retain claims and registry-based reporting."

HIMSS also requested CMS work more closely with the Office of the National Coordinator for Health IT to lessen "duplication and redundancies" related to surveillance and health information exchange, and that the agency help create more Medicare-focused Advanced APM options through, for instance, the Center for Medicare and Medicaid Innovation. It also asked CMS to broaden the role telehealth technology could play in helping meet requirements. Read HIMSS' full comments here.

The American Medical Association, meanwhile, offered a list of steps CMS should take to ensure  physicians can adequately transition to MIPS and APMs, and "have time to adopt and invest in practices that result in improved patient care."

[Also: As MACRA comment period winds down, MIPS scoring is 'mathematical marvel,' MGMA tells CMS]

Chief among them: a transitional reporting period for the first year – beginning July 1, 2017 – that would allow clinicians enough time to prepare for MACRA's far-reaching changes to care delivery and reimbursement.

More help and flexibility for solo docs and small practices (lower reporting burdens, ability to benchmark against peers, more training and technical assistance) is also key, said AMA, as is "timely and actionable feedback on their performance" from CMS.

Specific to MIPS, AMA said CMS should better align its components so the reimbursement framework "operates as a single program rather than four separate parts." When it comes to reporting, there should be the chance for partial credit and fewer required measures. Thresholds for quality reporting should stay at 50 percent.

And as for MIPS' Advancing Care Information component, CMS should "score and restructure the EHR performance measures, rather than keeping the current Meaningful Use Stage 3 requirements," according to AMA.

For those practices looking to participate in Alternative Payment Models, the agency should "simplify and lower financial risk standards for Advanced APMs; Base the risk requirements on physicians’ Medicare revenues instead of total Medicare expenditures so physicians do not have to take risks for expenses outside their control; and provide more opportunities for APM participation." Read AMA's full comments here.

For its part, the Consumer Partnership for eHealth – led by the National Partnership for Women & Families – cheered CMS for making "person-centered uses of health information technology" central to its proposed MACRA programs.

But it too had ideas about ensuring proposed requirements do better enabling "well-coordinated, patient- and family-centered care."

Most notably, CPeH urged CMS to retire the "one patient" requirement, which calculates a providers' score on for the Advancing Care Information component of MIPS according to e-prescribing, patient access and secure messaging.

It recommends increasing the threshold to 5 percent of all patients in 2019, noting that keeping one-patient would "undermine CMS’ commitment to make patients and family caregivers true and equal partners in improving health through shared information and shared decision-making."

[Also: MACRA proposed rule: Good intentions from CMS but a burden for small practices, says doc]

But the partnership cheered CMS' focus on patient and family engagement, care coordination and health information exchange in the ACI performance score. It urged CMS to increase the impact of such performance measures by rewarding clinicians for improvement through bonus points. Read its full comments here.

The American Medical Group Association, meanwhile asked CMS to "increase possible pathways to participate in Medicare as an advanced Alternative Payment Models" and also aired its own qualms about the condensed time frame in the proposed rule.

"Eligible clinicians and medical groups will not have sufficient time to review and select appropriate quality measures and make the health information technology changes necessary to succeed under MIPS," according to AMGA.

AMGA also recommended that CMS develop pathways for Track 1 Accountable Care Organizations to qualify as advanced APMs and for Medicare Advantage participants to qualify under the all-payer category beginning in performance year 2019. Read AMGA’s comments here.

Twitter: @MikeMiliardHITN
Email the writer: mike.miliard@himssmedia.com

Like Healthcare IT News on Facebook and LinkedIn