HIMSS Submits Comment Letter on MACRA NPRM

In a June 27th letter to Andy Slavitt, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS),HIMSS offered it comments to the  Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician Focused Payment Models Notice of Proposed Rule Making (NPRM).  In the letter, HIMSS commends CMS for developing and executing a transparent and inclusive process in gaining stakeholder feedback in the preparation of this NPRM, and it applauded CMS’ efforts to minimize the administrative burden on organizations and clinicians.

In CMS’ effort to shift Medicare Part B to a value-based payment system, the NPRM encourages maximum participation in both the Merit Based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) tracks, while allowing the opportunity for customization, streamlined requirements, and flexibility.  However, HIMSS notes that in creating this flexibility, CMS is proposing a level of complexity that increases the burden on eligible clinicians (ECs)

With the short timeline from the release of the final rule to January 1, 2017 (the intended start of the first reporting period), HIMSS recommends that CMS change the reporting period for the Advancing Care Information Performance Category of MIPS to 90 days.  Additionally, for those ECs pursuing the APM Track, HIMSS proposes that they only are required to report for 90 days, with the threshold requirements prorated accordingly for ECs’ aggregate Medicare Part B payments for covered professional services and the number of patients who received covered professional services through the Advanced APM.

In addition, HIMSS asks CMS to redouble its efforts to educate the clinician community on the new Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requirements and ensure that the burden placed on individual and small practices is not too pronounced.  More specifically, HIMSS appreciates the flexibility in the new Advancing Care Information requirements, but cautions CMS to ensure that ECs have a path forward for success in this performance category and that the requirements are not overly burdensome.  HIMSS recommends that CMS moderate the complexity of Quality reporting by reducing the number of available reporting methods available to meet MIPS reporting requirements as health IT reduces the need to retain claims and registry-based reporting.

Moreover, the letter also asks CMS to work more closely with the Office of the National Coordinator for Health IT (ONC) to reduce duplication and redundancies in the NPRM provisions on surveillance and health information exchange.  HIMSS also requests that CMS facilitate the creation of more Medicare-focused Advanced APM options through the Center for Medicare and Medicaid Innovation or other mechanisms.

Finally, HIMSS urges CMS to expand the role of both telehealth technology and program requirements in the MACRA Final Rule.  Overall, HIMSS states that it is important for achieving the goals and objectives of healthcare transformation to facilitate the use of remote patient monitoring and telehealth tools in MACRA implementation.

View Final Letter