Comments on CMS’s proposed rule for implementation of MACRA provisions

The Center for Health Policy, with support from the Schaeffer Initiative for Innovation in Health Policy, a partnership between Brookings and the University of Southern California, submitted comments on a proposed rule to the Centers for Medicare & Medicaid Services (CMS) 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.

We applaud the efforts CMS has taken to solicit and respond to feedback particularly toward the proposed rule. We believe the currently proposed rule moves Medicare physician payment in the right direction, and we offer three suggestions to further improve MACRA implementation by better supporting providers’ pipeline to APMs.

MACRA established incentives intended to spur greater provider participation in APMs that meet certain qualifying criteria. As a reward for meeting these conditions, providers will receive an automatic 5% bonus for the first six years of the program and, from 2026 onward, a base rate increase three times as much as providers in MIPS — .75% versus .25%. Since, unlike MIPS, the Advanced APM track is not budget neutral, it offers the real chance to drive cost savings. However, CMS estimated in the proposed rule that as few as 4% of Medicare physicians may qualify into the Advanced APM track in its first year.

We suggest three ways in which CMS can further achieve its stated goal to “expand the opportunities for participation in APMs” by better supporting providers’ transition under MACRA. These suggestions are to: 1) identify ways to increase the number of existing Medicare APMs that qualify as Advanced APMs; 2) establish a multi-year plan for new models that begins with initial minimal risk and grows to require more risk over time; and 3) allow eligible clinicians to qualify either as individuals or as a part of an APM Entity.

Read the full comments on the proposed rule for the implementation of provisions of MACRA