The California Medical Association (CMA) submitted comprehensive comments to the Centers for Medicare and Medicaid Services (CMS) outlining constructive improvements for the implementation of the Medicare Access and CHIP Reauthorization Act (MACRA).

The MACRA law clearly mandated CMS to simplify and reduce the burdensome reporting programs as well as incentivize innovative new payment models led by physicians. CMA outlined the most serious areas of concern with the proposed rule, including:

  • The accommodations for solo, small and rural practices are inadequate.
  • The MIPS reporting programs continue to be unnecessarily burdensome and complex, particularly the electronic health record (EHR) Advancing Care Information category.
  • There is no accountability for EHR vendor compliance and interoperability.
  • The MIPS Resource Use category will continue to discourage physicians from treating high-risk, vulnerable patients.
  • The Advanced APMs are limited and the financial risk requirements severely inhibit the expansion of innovative APMs.
  • The performance reporting period starts too soon—January 1, 2017.

CMA’s MACRA Technical Advisory Committee developed over 40 practical recommendations to simplify and improve the implementation of MACRA. In addressing the issue of participation for small practice and solo practice physicians, CMA suggested that the initial reporting period be moved back one year to January 1, 2018, and that CMS significantly expand the permanent MIPS low-volume exemption for small practice physicians and physicians located in health professional shortage areas.

CMA also suggested that there should be a phase-in pathway to help small and rural practices transition to MIPS, as well as safe harbors for small practices until virtual group reporting systems can be established. CMA also recommended that Medicare-Medicaid dual-eligible patients be excluded from the scoring system so physicians are not penalized for treating these complex patients.

In addressing the regulatory burdens of MIPS reporting programs, CMA recommended improvements to four reporting programs (quality, EHR advancing care information, resource use and the clinical improvement activities) that include reducing the scoring complexity of these programs. While CMS reduced nearly half of the quality measures, CMA is urging that more measures be eliminated, particularly the irrelevant EHR Meaningful Use Stage 3 measures, and that physicians should be given partial credit for any measures that are met, rather than an all-or-nothing approach. CMA also placed great emphasis on CMS holding EHR vendors more accountable for compliance and interoperability.

Finally, CMA urged CMS to provide more opportunities for physician-led payment models with reduced financial risk requirements and to extend the deadlines for physicians to participate in the Comprehensive Primary Care Medical Home models with private payors.

To read the full CMA letter,

click here.

CMA will be hosting a webinar, "MACRA: What is CMA Doing to Improve It? What Steps Can You Take to Prepare Now?," on Wednesday, July 13, 2016 at 12:15 PM. Click here for more information or to register.

For questions, contact the ACCMA at 510-654-5383 or