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    August 21, 2017  

    The Honorable Seema Verma
    Centers for Medicare & Medicaid Services
    Department of Health and Human Services
    200 Independence Avenue, SW
    Washington, DC 20201

    RE: Medicare Program; CY 2018 Updates to the Quality Payment Program

    Dear Administrator Verma:

    The Medical Group Management Association (MGMA) is pleased to submit the following comments in response to the final rule with comment period entitled, “Medicare Program; CY 2018 Updates to the Quality Payment Program,” published on June 30, 2017, with file code CMS–5522–P. The Association welcomes many of the proposals in this rule that would afford physician group practices with stability and flexibility during the second year of the Quality Payment Program (QPP) and offers recommendations to reduce burden in the Merit-Based Incentive Payment System (MIPS) and support physician practices as they transition to alternative payment models (APMs).

    MGMA is the premier association for professionals who lead medical practices. Since 1926, through data, advocacy and education, MGMA empowers medical group practices to create meaningful change in healthcare. With a membership of more than 40,000 medical practice administrators, executives, and leaders, MGMA represents more than 12,500 organizations of all sizes, types, structures, and specialties that deliver almost half of the healthcare in the United States.

    Repealing the problematic sustainable growth rate and retiring a hodgepodge of quality reporting programs, the Medicare Access and CHIP Reauthorization Act (MACRA) charted a value-based trajectory for the Medicare payment system by valuing innovative, patient-centric and efficient care delivery over check-the-box bureaucracy. However, as implemented by the previous Administration, MIPS is overly complex and rewards the quantity of reporting rather than the quality of care provided to patients. At the same time, the Advanced APM pathway is far too narrow. At this critical juncture in Medicare’s transition from fee-for-service toward value-based reimbursement, CMS has an opportunity to reset and align the QPP with the original intent of MACRA to support physician practices as they transform the way they deliver care.

    According to a recent study of more than 750 MGMA member practices, the QPP is the most burdensome regulatory issue facing group practices in 2017. Although the vast majority of respondents are participating in MIPS, more than 70% of respondents were very or extremely concerned about the lack of clinical relevance to patient care. Articulating a theme we hear regularly across the country, one practice leader wrote: “We are a GI single specialty clinic. I can use the specialty measures for the MDs but not the mid-level providers as they don’t apply. I have to have two sets of MIPS requirements and measures. It’s extremely burdensome.”

    Similarly, a 2016 Health Affairs study of MGMA member practices cited in this proposed rule (82 Fed. Reg. 30219) found that each year physician practices in four common specialties spend, on average, 785 hours per physician and more than $15.4 billion on quality measure reporting programs. As the study cites, the majority of time spent on quality reporting consists of “entering information into the medical record only for the purpose of reporting for quality measures from external entities,” and nearly three-quarters of practices stated their group was being evaluated on quality measures that were not clinically relevant. Congress recognized the pitfalls of these programs in driving clinicians’ time away from patients and toward paperwork, and, as a result, replaced them with MIPS.

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