NCDR® UPDATE
Role of Registries Included
in New ACC Comments on
Proposed MACRA Rule
O
n June 27, the ACC submitted extensive
comments to the Centers for Medicare and
Medicaid Services (CMS) on the proposed
regulations to implement the Medicare Access and
CHIP Reauthorization Act of 2015 (MACRA) based
on the feedback of key member groups, including
the College’s Health Affairs Committee, Partners in
Quality Subcommittee, MACRA Task Force, NCDR®
Management Board, the Health Information Technology (Health IT) and Informatics Task Force, and
several member sections and workgroups.
The MACRA legislation repealed the flawed Sustainable Growth Rate (SGR) formula, which focused
on fee-for-service payment, where higher performing
physicians had no ability to earn more for outcomes.
Replacing SGR with MACRA will pave the way for a
new payment system that places importance on quality care. MACRA also creates stability for Medicare
payments by mapping out payment updates for 10
years and beyond—stability that was severely lacking under the SGR formula. These regulations will
establish rules for clinician participation in both the
Merit-Based Incen tive Payment System (MIPS) and
qualifying for incentive payments based on participation in Advanced Alternative Payment Models
(APMs) beginning with the 2019 payment year.
In the comments to CMS, the ACC noted the
complexity of implementing a new payment model
like MACRA and agreed that simplified education
and assistance from CMS will be needed to ensure
that members are prepared for implementation. The
ACC encouraged CMS to revise policies to allow
clinicians reporting data as a group to report and
be scored on the most relevant measures to their
clinical practice. The College recommended that
clinicians be “held harmless” from penalties if it
becomes apparent that clinicians are having trouble
transitioning to the new policies.
Other key comments from the ACC include:
• Refining the “low volume” MIPS exemption
threshold to make it more available to cardiologists, particularly those in small practices and
those treating a primarily pediatric or non-Medicare population.
36 CardioSource WorldNews: Interventions
The ACC noted
the complexity
of implementing
a new payment
model like MACRA
and agreed that
simplified education
and assistance from
CMS will be needed.
• Refining the “non-patient facing” clinician definition to ensure that the flexibility offered under this
category is available to cardiologists, particularly
imaging specialists. The ACC also advocated that
quality improvement initiatives performed as part
of laboratory accreditation be recognized as clinical practice improvement activities under MIPS.
• Recommending how CMS should provide
clinicians with clear and actionable feedback
to ensure that they understand their reporting
requirements and whether or not they are successfully meeting criteria.
• Recommending that CMS increase flexibility
for the Advancing Care Information component
of MIPS (formerly Medicare Electronic Health
Record [EHR] Incentive Program, also referred to
as Meaningful Use) to provide opportunities for
success, including a delay in requiring the 2015
Edition EHR certification.
• Strongly opposing the proposal to substantially increase the successful reporting threshold
from 50% to 80% or 90% of all applicable patients, despite ACC’s support of the collection
of all-payer data to improve the sample size for
quality reporting.
• Recommending a cautious approach to the implementation of new episode groups for measuring
clinician cost and resource use. The ACC warned
CMS of the complexity of measuring clinician cost
performance, especially when treating patients
with chronic conditions.
• Supporting a process in which clinicians and
groups can request that CMS review their MIPS
data if they believe that the Agency has assigned
an incorrect score or penalty.
• Supporting CMS’ recognition of the role of
registries in quality improvement, including proposals to have Qualified Clinical Data Registries
such as NCDR’s PINNACLE Registry and the
Diabetes Collaborative Registry accepted as a
MIPS reporting mechanism and clinical practice
improvement activity.
• Highlighting the need to make participation in
APMs recognized under the MIPS APM and
Advanced APM pathways more available to cardiologists, including recommendations to consider
models such as the Bundled Payments for Care
Improvement (BPCI) program as a MIPS or Advanced APM.
CMS will release the final regulations by Nov. 1,
2016, which will go into effect on Jan. 1, 2017—
the proposed start of the reporting period under
the new payment program. The ACC will continue
to work with CMS throughout the regulatory process to establish details of how the law will function. The ACC will also be developing education and
resources to help members prepare for the changes
ahead. Stay tuned to ACC.org/MACRA for the latest
information and resources. ■
July/August 2016