Statement” published in July. Access the position statement at tma.tips/ MACRAposition. In its formal comment on the rule,
TMA made several recommendations to ease the burden for small practic- es. (See “50 Ways to Fix MACRA,” at right.) For example, TMA estimates physicians who bill less than $250,000 in Medicare charges will spend more trying to comply with the rule than they could ever earn in bonuses. TMA recommended any physicians who bill less than that amount be exempt from MACRA. CMS set the “low-volume threshold” in the proposed rule at just $10,000. CMS Acting Administrator Andy
Slavitt has publicly acknowledged doctors’ vast discontent with the cur- rent system and has gone out of his way to solicit practicing physicians’ suggestions for improvement. He sees the agency’s plan, however, as consis- tent with congressional intent. MACRA, Mr. Slavitt told the U.S.
Senate Finance Committee in mid- July, “allows physicians and other cli- nicians to participate in a single, sim- plified program with lower reporting burdens and new flexibility in deliver- ing quality care.” That comment drew a quick re-
buttal from Gregory M. Fuller, MD, chair of the TMA Council on Health Care Quality. “Mr. Slavitt has heard what physicians have been saying is a major barrier to MACRA: increased complexity, increased bureaucracy,” Dr. Fuller said. “The goal of MACRA is to improve health care quality and decrease cost, not cause physicians to drop out of Medicare or retire.”
MASSIVE CHANGE, SHORT TIMELINE The MACRA law, Mr. Slavitt ex- plained in a speech earlier this year, intends “to make a wholesale change in the Medicare payment system to pay for quality.” The gargantuan, 962- page proposed MACRA rule CMS published in May underscores the magnitude of that change. In SGR’s place, MACRA requires
50 WAYS TO FIX MACRA
TMA sent the Centers for Medicare & Medicaid Services (CMS) a detailed formal comment letter with 50 recommen- dations to improve the agency’s proposed rule to implement the Medicare Access and CHIP Reauthorization Act (MACRA). Read the full letter at tma.tips/MACRAcomment. The most critical of TMA’s 50 recommendations are:
• Significantly expand the low-volume threshold. According to TMA’s analysis, physicians who bill less than $250,000 in Medicare charges will spend more trying to comply with the MACRA rule than they could ever earn in bonuses, if they hit the quality targets. CMS set the low- volume threshold at $10,000 in Medicare allowed charges. TMA told CMS to set the threshold at $250,000. Doing so would exempt physicians who have no possibility of a posi- tive return on their investment in the cost of reporting. For physicians with less than $250,000 of Medicare revenue, reporting should be optional, and physicians who attempt compliance should be exempt from any payment penalties.
• Delay the start. The rule will be finalized around Nov. 1. Practices will have to begin collecting data and making big changes in their operations on Jan. 1. This gives physicians only two months to prepare. TMA told CMS the measure- ment period for 2017 should be reduced to six months and start no sooner than July 1. (The data collected in 2017 affects physicians’ Medicare payments in 2019.)
• Set the performance threshold low. The performance threshold (PT) is the most important factor affecting MACRA’s overall impact on small practices. CMS has complete discretion to set the PT, which is the score a physician must earn to avoid penalties. The threshold also will determine how much MACRA will shift Medicare payments from smaller physician practices to larger groups and health care systems. To reduce the negative impact on small practices, TMA urged CMS to set the PT at 15 percent in the first year of implementation.
September 2016 TEXAS MEDICINE 43
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