The American Medical Group Association and Medical Group Management Association have both weighed in with the Centers for Medicare and Medicaid Services about CMS' proposed rules on reducing regulatory burden – and both want changes.

WHY IT MATTERS
For its part, AMGA offered a list of suggestions CMS should take to cut back on Medicare's regulatory complexity and help free up physicians to deliver better care.

Among them the group asked the agency to reconsider several policies in the Medicare Shared Savings Program, and waive its Appropriate Use Criteria for providers participating in value-based reimbursement models – but said MSSP waivers should be available to providers at all levels of risk, since different sets of rules would hinder more providers from being ready for the transition into risk-bearing model

AMGA also asked CMS to rethink several of its documentation and reporting requirements, especially those that don't improve care delivery or workflow processes.

For instance, "current quality reporting continues to be burdensome, contributing to burnout and added costs for providers," the group argued in its letter to CMS Administrator Seema Verma. "Research has indicated that annually U.S. physician practices in four common specialties spend more than $15.4 billion and, on average, 785 hours per physician to report quality measures.

"Additionally, our own members have reported the cost and burden associated with measure reporting. For example, a 2017 AMGA survey found that for every 100 physicians our members employ, 17 information technology professionals were needed to support them. These costs are much better spent on caring for patients, not maintaining an expensive IT infrastructure."

The Medical Group Management Association, meanwhile made the case that, while it's an improvement over the "problematic sustainable growth rate" and an accompanying "hodgepodge of quality reporting programs," Merit-based Incentive Payment System "remains an overly complex program that rewards the quantity of reporting rather than the quality of care provided to patients."

In its letter to CMS, MGMA asked the agency, among other things, to:

• Decrease the number of measures across MIPS.
• Simplify MIPS and reduce redundancies by awarding cross-category credit.
• Provide clear and actionable feedback regarding MIPS performance at least every calendar quarter.
• Refine the low-volume threshold application to group practices.
• Release critical MIPS information prior to the start of the performance period.
• More clearly delineate any changes made mid-year to QPP measure specifications, benchmark files, or other technical documents that may impact current year reporting.

THE LARGER TREND
When the agency unveiled its Patients Over Paperwork initiative, CMS Administrator Seema Verma said too much needless documentation is adversely impacting physicians' ability to do their jobs: "This is a poor use of their time," she said. "We are not leveraging the value of American clinicians."

Since then the stories of physician burnout have continued to proliferate.

CMS issued a request for information this past June, seeking ways to improve the program.

“In step with the Trump Administration’s Cut the Red Tape initiative to reduce overly burdensome regulations across the federal government, Patients over Paperwork has made great inroads in clearing away needlessly complex, outdated, or duplicative requirements that drain clinicians’ time but contribute little to quality of care or patient health," said Verma.

ON THE RECORD
"Our members are treating patients through delivery models that hold them accountable for the cost and quality of the care they provide," said Dr. Jerry Penso, AMGA president and CEO. "These models by design do not contain the same misaligned incentives seen in the fee-for-service environment, and Medicare’s rules and policies need to recognize and account for this difference."

"CMS’s Patients over Paperwork initiative has been in place since 2017 and the results have been modest. In fact, 86% of MGMA members reported an increase in regulatory burden last year," said Anders Gilberg, senior vice president of government Affairs at MGMA. "There is a tremendous amount the administration can do to reduce the regulatory burden on medical practices. CMS has gathered more than enough feedback from the physician community at this point and should focus on implementation over information."