AAOS Comments on MACRA
The Centers for Medicare & Medicaid Services (CMS) recently announced a Request for Information (RFI) for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Specifically, the RFI solicits input on the implementation of select provisions of MACRA including aspects of the Merit-Based Incentive Payment System (MIPS), developing and promoting alternative payment models (APMs), and encouraging creating physician-focused payment models (PFPMs).
“AAOS believes CMS must work closely with AAOS and other specialty societies throughout the drafting process,” stated David D. Teuscher, MD, President of AAOS in comments to CMS. “As specialty physicians, orthopaedic surgeons face unique technology challenges, ranging from certification issues to collection of specialty-appropriate data, as well as the larger issues impacting all physicians such as interoperability and cost. We appreciate CMS’s efforts in providing resources to the health care community, but because surgical specialists have unique Health Information Technology (HIT) needs, we believe CMS needs to develop improved, specialty-specific tools. As noted in previous communications, the AAOS is ready to work with CMS in establishing specialty-specific standards and performance measures for all orthopaedic treatment domains.”
AAOS stressed that in order to implement all of the proposed standards in MACRA, orthopaedic surgeons would spend an excessive amount of time directly entering patient data not essential to the diagnosis and treatment of musculoskeletal conditions or injuries into their EHR systems. However, AAOS reminded CMS that orthopaedic surgeons are better served concentrating their time and efforts in recording data that are germane to the musculoskeletal issues for which the patient seeks his or her care, and not on non-essentials elements of the patients’ history.
Because infrastructural support remains incomplete – with meaningful use attestation below 20 percent – the AAOS also strongly recommended that prior to MACRA implementation, CMS first demonstrate infrastructural readiness on a meaningfully nationwide level. By making infrastructure readiness a condition of MACRA implementation, CMS will have time to monitor progress and determine what is and is not working to incentivize infrastructure development.
Additionally, the AAOS urged CMS to carefully review and evaluate current alternative payment models tested under CMS (and private payer) initiatives such as the BPCI program. These initiatives are ongoing and it is incumbent on CMS to validate alternative payment model success both in terms of cost savings and most importantly, the quality of patient care and improved outcomes. Further, the AAOS emphasized that it strongly supports voluntary bundled and episode-of-care pilot projects, as opposed to the recent mandatory bundled payment program announced by CMS (read more online here).
“The AAOS is appreciative of CMS’ focus on aligning various physician payment, efficiency, and quality improvement reporting programs to reduce the burden on eligible professionals and group practices that participate in those programs,” said Dr. Teuscher. “[We look] forward to working closely with CMS to ensure physician payment reform ultimately improves the care of musculoskeletal patients.”