As MACRA comment period winds down, MIPS scoring is 'mathematical marvel,' MGMA tells CMS

The physician practice association offered recommendations for the Merit-Based Incentive Payment System and Alternative Payment Models proposed by MACRA – including a reduction of reporting requirements across MIPS.
By Jessica Davis
11:21 AM

As it stands, the Merit-Based Incentive Payment System doesn't allow enough time for physicians, practices and trading partners to prepare for proposed changes in workflow, investments and system requirements, the Medical Group Management Association told Andy Slavitt, acting administrator of the Centers for Medicare and Medicaid Services in a letter on June 24.

MGMA, which represents medical practices around the country, submitted comments on the MIPS and Alternative Payment Model proposals outlined in the proposed Medicare Access and CHIP Reauthorization Act, or MACRA.

Comments on the proposed ruling are due to CMS at 5 p.m. today.

While MGMA applauds both the intention and efforts of the government to streamline the program for a more patient-centric and flexible program, the group stated there is not enough time to accomplish the goals.

"Starting performance on Jan. 1, 2017, as proposed, would, at best, reduce MIPS participation from a thoughtful and concerted effort to improve the value of patient care into a sprint toward compliance out of sheer survival," the authors said in the letter.

"Or quite possibly evolve into a winner take-all scenario in which the practices that have already made investments in infrastructure and technology would excel, while less-resources practices scramble to catch up or decide not to participate," they added.

Instead, MGMA proposed to push back the performance period start-date to at least Jan. 1, 2018. The group said CMS must also devote "significant resources" to educate practices. Additionally, MGMA proposed to reduce the reporting requirements across MIPS, as "physician group practices' finite resource would be spread across at least 20 measures and objectives."

The proposed scoring system for MIPS "is nothing short of a mathematical marvel," Halee Fischer-Wright, MD, MGMA president and CEO, said in a statement. Meanwhile, MACRA's "narrow definition of APM provides almost no opportunities for medical groups to begin the shift away from fee-for-service reimbursement."

Among other proposed changes, MGMA urged CMS to finalize the MIPS group practice assessment option; award credit across MIPS performance categories to streamline the program and reduce any redundancies; and re-weight the MIPS resource use performance category to zero until "CMS has extensively tested" proposed new episode-based measures.

"MGMA appreciates the significant outreach from CMS leadership in recent weeks and is hopeful the agency will take our feedback and implement a simplified system that offers significantly more choices for physicians and supports their ability to provide high quality patient care," said Fischer-Wright.

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