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FEDERAL | ASPS Joins Call for Measured Approach to MACRA Implementation

This month, ASPS joined a significant push by organized medicine to encourage Congress to extend the Centers of Medicare and Medicaid Services' (CMS) flexibility in implementing the Quality Payment Program (QPP). The QPP, created by the Medicare Access and Chip Reauthorization Act (MACRA), is in its first year, during which the requirements for successful participation were dramatically reduced by CMS. CMS was able to make these adjustments while implementing the QPP because of the way MACRA was originally written. This statutory flexibility expires after the second year of the program, necessitating the current effort to see it extended.

ASPS signed letters by the American Medical Association and the Alliance of Specialty Medicine, which has also been conducting congressional meetings on this issue in recent weeks. The letters highlight the successful collaboration between organized medicine and CMS to develop the initial implementation of the QPP, during which the program was recalibrated to position it for success. These recalibrations were designed to get the program off the ground while allowing physicians to acclimate to the QPP without exposure to significant financial penalties. For example, to account for the lack of readiness of resource use measures in the first year of the Merit-based Incentive Payment System (MIPS), CMS used its administrative prerogative to "zero out" the weight of the resource use component of MIPS. ASPS also joined other medical societies in asking for an extension in the Secretary of the U.S. Department of Health and Human Services' (HHS) ability to select a performance threshold during the first two years that is other than the "mean or median" standard. Gradual increases of this performance threshold – which is the baseline on which all MIPS participants will be either rewarded or penalized – helps physicians adjust to the new program before facing serious financial downside.

While an easier path to successful participation was a boon to physicians in 2017, it was also critical to CMS, which has been slow to finalize critical aspects of the QPP. Struggles in refining cost measures, data submission and feedback pathways, specialty quality measure sets and the shape of the program's virtual group option all suggest that a continuation of the current, measured approach is necessary. CMS soon will be required to publish proposed rules to cover the program's third year of operation, and only new legislation can extend CMS' timeline for finalizing all aspects of the QPP.