Commentary: Make your voice heard on MACRA

Stakeholders have until June 27 to weigh in with the Centers for Medicare and Medicaid Services. Why should you? Experts say the Medicare Access and CHIP Reauthorization Act is an aggressive and transformational piece of rulemaking.
By Mike Miliard
10:45 AM

When the Centers for Medicare and Medicaid Services released the notice of proposed rulemaking for the Medicare Access and CHIP Reauthorization Act, or MACRA, it made a big deal of the fact that the carefully-crafted rule was based on "unprecedented" levels of input from frontline clinicians.

"We spoke with over 6,000 stakeholders across the country, including clinicians and patients, in a variety of local communities," said Acting CMS Chief Andy Slavitt in announcing the new rule, with its Merit-based Payment System, or MIPS, whose Advancing Care Innovation component would replace meaningful use for Medicare physicians.

Listening to stakeholders is good.

Not so good? The verdict on the proposal delivered by Beth Israel Deaconess Medical Center CIO John Halamka, MD, who said he spent 20 hours reading all 962 pages of the notice.

"The folks at CMS are very smart and well meaning, but it’s hard for me to imagine implementing the NPRM as written in the timeframes suggested," wrote Halamka on his blog.

[Also: A deep dive on the 'overwhelmingly complex' MACRA proposed rule]

Remarkably, Halamka went on to write that, "as a practicing clinician for 30 years, I can honestly say that it’s time to leave the profession if we stay on the current trajectory."

In a subsequent post, Halamka clarified some of those thoughts. But his initial alarm was hard to ignore.

At any rate, he wasn't quite ready to give up hope – and said he was withholding judgement until public feedback had been logged and digested.

"I will watch closely for comments from organizations such as the AMA, AHA and clinician practices," Halamka wrote. "Maybe the upcoming presidential transition (whoever is elected) will give us time to pause and reflect on what we’ve done to ourselves."

CMS has the best of intentions, of course. It wants physicians to use technology to the best of their abilities, to deliver the best possible care. The agency engaged in "extensive sessions and workshops" to find the optimal way of enforcing that will being sensitive to physicians' needs, said Slavitt.

In doing so, CMS learned that a "near-universal" vision shared by those they spoke to looked like this, he said: "Physicians, patients, and other clinicians collaborating on patient care by sharing and building on relevant information."

The response, then, was to keep emphasis on interoperability and data exchange, prioritizing plug-and-play technology tailored to unique workflows, while offering physicians a flexible reporting structure in place of the much-maligned meaningful use.

Advancing Care Information is meant to do that, said Slavitt – allowing clinicians to pick the measures that best reflect how they use IT, streamlining and simplifying reporting requirements, aligning with ONC's 2015 certification criteria (which require APIs for easier patient access), exempting certain physicians and more.

But it's not quite so simple. Quite the opposite, arguably: The rules put forth in MACRA "are so overwhelmingly complex that no mere human will be able to understand them," Halamka wrote.

As John Goodson, MD, associate professor at Harvard Medical School told Healthcare IT News recently, this new framework, billed as a more palatable replacement for burdensome meaningful use, is simply "a whole new set of complications and implications."

MACRA is a "transformational" piece of rulemaking, Goodson said. "They're being extraordinarily aggressive." 

[Also: MACRA proposed rule: Good intentions but a burden for small practices]

Not least on the timing of it all. Reporting for Advancing Care Information would begin January 1, 2017. As hard as it is to think about the winter as June blooms, that's pretty soon.

Even sooner, though, is June 27, 2016 – the last day for public comment of the proposed rule.

Goodson thinks there will be "a lot of pushback" on that 2017 reporting start. "There's going to be some backing down just because of the logistics of this and because it's going to take a while for providers to make these adjustments."

But none of that will happen if physicians don't offer their feedback, early and often.

Hospitals, currently unaffected by the proposed rule, could eventually be in for a change too, by the way: "We are already meeting with hospitals to discuss potential opportunities to align the programs to best serve clinicians and patients," said Slavitt the same day the NPRM was published in April.

In May, he spoke to the American Hospital Association: "We need meaningful engagement on this proposal," he said.

All industry stakeholders owe it to CMS – and themselves – to take his advice to heart.

This commentary originally appeared in the June issue of Healthcare IT News. Access the digital edition here. 

Twitter: @MikeMiliardHITN
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