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July 5, 2016

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AAOS Comments on CMS Proposed Rule for Physician Reimbursement

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HHS Announces Initiative to Help Small Practices Prepare for the Quality Payment Program

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AAOS Comments on CMS Proposed Rule for Physician Reimbursement

On Friday, June 23, 2016, the AAOS submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule for the physician reimbursement framework required under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The new framework replaces the flawed Sustainable Growth Rate (SGR) formula, and offers details on two reimbursement options: the Merit-based Incentive Payment System (MIPS), and Advanced Alternative Payment Models (APMs).

The AAOS expressed support for CMS’ efforts to reduce the administrative burden and required quality measures on clinicians. The proposed legislation’s greater flexibility of reporting requirements will eventually help streamline multiple Medicare physician reporting programs into a single system; however, the regulations, tentatively to be finalized in the fall of 2016, will create a significant burden on physicians who are preparing for the first performance year in 2017. Additionally, the persistent challenges in the “meaningful use” program—including interoperability and infrastructure readiness—will likely carry over to MIPS, creating obstacles to successful reporting for physicians.

The comments also addressed other concerns: the extended reporting period of one year; lack of access to data; and the potential impact MACRA would have on smaller or solo practices.

Finally, the AAOS expressed disappointment that the proposed rule did not include either the Bundled Payments for Care Improvement (BPCI) models or the Comprehensive Care for Joint Replacement (CJR) model as Advanced APMs. Exclusion of the CJR model—initiated in April of 2016 and mandatory in 67 areas in the U.S.—in the proposed rule is inconsistent with the intent of the MACRA legislation and CMS goals. Because of the model’s scope and its inclusion of quality measures, advancing care information requirements, clinical improvement activities, and risk bearing requirements, the AAOS believes that the CJR model should already qualify as an Advanced APM. However, the AAOS comments also suggested changes to the CJR model: switching to a physician rather than hospital leadership and incorporating double-sided risk-bearing by physicians. Further, AAOS emphasized the restrictive requirements to qualify for Advanced APM status and suggested CMS reconsider the definition of nominal total risk.

“AAOS is thankful for the opportunity to comment on this proposed rule and looks forward to engaging with CMS to ensure MACRA provisions ultimately improve the care of musculoskeletal patients,” said AAOS President Gerald R. Williams, Jr., MD. “Patient care is of the utmost importance. While many provisions in the proposed rule are improvements over the current system, there are a number of steps that would better protect specialty physicians along with small and solo practices so that Medicare patients have access to the timely, high-quality, affordable specialty care that they need. We are hopeful that CMS will take seriously these concerns and we will continue working to improve care delivery for all Americans.”

For further information, visit www.aaos.org/macra or read the entire AAOS comments to CMS online here.