AMDA Submits Comments on MACRA RFI

November 20, 2015
Health Policy

This week AMDA, submitted comments to the Centers for Medicare & Medicaid Services (CMS) on their Request for Information (RFI) regarding the implementation of Alternative Payment Models (APMs) and Merit-Based Incentive Programs (MIPS) under the Medicare Access and CHIP Reauthorization Act (MACRA).

AMDA noted that “if properly implemented, the new physician payment framework will promote improvements in the delivery of care to Medicare patients.” To help clinicians make the transition to new care and delivery models and ensure access to high-quality care for all patients, AMDA urged the Administration to carefully consider and adopt overall principles that include:

  • Providing an equitable payment system that incentivizes quality health care for a diverse patient population.
  • Aligning with patient goals of care.
  • Streamlining quality reporting.
  • Promoting workforce development and competencies to care for the post-acute and long-term care (PALTC) population.
  • Reducing administrative burden.

AMDA also noted the unique nature of PALTC practice, asking CMS to “continue to address measurement gaps and to improve the existing set of measures. Smaller organizations have a more difficult time finding funding to develop quality measures that are relevant to their patient population. We reiterate our concern that CMS has not yet allocated MACRA-authorized funding toward this effort, and we urge the agency to do so as expeditiously as possible. AMDA has been a clinical leader in the practice of PALTC medicine. We have developed a number of evidence-based clinical practice guidelines (CPGs) that serve as guidance for highest quality of PALTC” AMDA strongly urged the Agency to “work with organizations like AMDA to provide the necessary support and funding to develop clinically relevant and appropriate quality measures that truly reflect the quality of care provided in PALTC.”

AMDA’s comments also reinforced the long standing issue with the attribution methodology, inappropriate comparison groups, and ineffective risk stratification that set up disincentives to practice for PALTC practitioners with the current value-based modifier (VM) cost measures. “CMS needs to devote significant data analysis and resources to this effort in order to replace, not expand, the current VM cost measures.”

To read all of AMDA’s comments click here.