PCPCC Responds to Proposed MACRA Regulations

On June 27, 2016 the PCPCC responded to the Centers for Medicare & Medicaid Services (CMS) with its official comments on the Medicare Access and CHIP Reauthorization (MACRA) proposed rule.

As a key supporter of payment reform embodied in MACRA, we appreciate CMS’ substantial work in crafting proposed regulations that seek to implement this critically important and complex statute. Leading a careful, clear, and workable implementation of this historic law is an immense challenge, but its importance cannot be overstated. 
The PCPCC is particularly supportive of provisions in the MACRA proposed rule that:
  • Acknowledge the key role of Patient-Centered Medical Homes in health system delivery reform. 
  • Improve Quality Measurement and Reporting, to include Patient Reported Outcome Measures. 
  • Advance the Comprehensive Primary Care Plus (CPC+) program as an Advanced Alternative Payment Model.
  • Promote New Categories within the Clinical Practice Improvement Activities (CPIA), including Achieving Health Equity and Integration of Behavioral and Mental Health.
  • Elevate the Physician-Focused Payment Model Technical Advisory Committee (PTAC) 
Despite the complexity of the law itself, the proposed rule in its current form is cumbersome and ill-timed, misses the mark on opportunities to simplify and streamline aspects of performance measurement, and unnecessarily limits the scope and spread of the medical home model of care that could enhance health care delivery to beneficiaries across the US. 
The PCPCC offers specific suggestions for improving the implementation of MACRA:
  • Embrace Medical Homes as Advanced Alternative Payment Models
  • Expand Accreditation of Patient-Centered Medical Homes to other recognition programs that have a demonstrated track record
  • Acknowledge the Challenges of Solo and Small Group Practices by promoting virtual groups
  • Change the Implementation Timeline to Give Clinicians More Time to Prepare
  • Streamline Quality Measurement by including the Core Measure Set
  • Strengthen Beneficiary Engagement at All Levels of Care
As a unique coalition representing health care providers, patients, and payers, the Collaborative stands ready to assist CMS in engaging the diversity of organizations keenly interested in supporting payment reform that supports high-performing team-based patient-centered primary care for all. We respectfully request consideration of our recommendations to simplify, spread, and scale high-performing primary care.
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