Government Advocacy

March 22, 2018: MGMA statement for Ways and Means MACRA implementation hearing

Advocacy Statement

Medicare Payment Policies

Medical Group Management Association

Statement for the record

Committee on Ways and Means
Subcommittee on Health
United States House of Representatives

Re: Implementation of MACRA’s Physician Payment Policies

Anders Gilberg, MGMA
Senior Vice President, Government Affairs
agilberg@mgma.org

1717 Pennsylvania Ave NW Suite 600
Washington, DC 20006
202.293.3450
(f) 202.293.2787

March 22, 2018

WASHINGTON, D.C. – The Medical Group Management Association (MGMA) commends the Committee on Ways and Means Subcommittee on Health for convening this hearing on “Implementation of MACRA’s Physician Payment Policies.” MGMA represents 12,500 medical group practices of all sizes, specialties, types and structures, which collectively provide almost half of the healthcare in the United States.

MGMA appreciates Congress’ ongoing leadership and oversight efforts to ensure successful implementation of the sweeping payment reforms enacted in the Medicare Access and CHIP Reauthorization Act (MACRA). We applaud Congress making technical corrections to MACRA in the Bipartisan Budget Act, another example of its continued support for the innovative care delivery improvements taking place in group practices across the country. We are optimistic that these changes will be a catalyst for improving the Merit-based Incentive Payment System (MIPS) beginning in 2019 and expanding Advanced Alternative Payment Model (APM) opportunities in the near future.

Since MACRA passed, MGMA has partnered with Congress and the administration to help physician practices succeed in the Quality Payment Program (QPP). We have hosted numerous educational events that connect our members directly with Centers for Medicare & Medicaid Services (CMS) staff, served as informational and educational resources for our members by dispensing news and information related to MIPS, and provided suggestions to policy makers based on feedback from our members. On March 15, MGMA offered several MACRA-specific recommendations to this Subcommittee at the “Red Tape Relief Initiative” Roundtable. We also collaborate with other stakeholder groups as part of various coalitions, including a MIPS workgroup that submitted to CMS comprehensive suggestions for reducing clinician burden, several of which are reflected in these comments. 

We appreciate Congress’ work to support physician practices transitioning to value-based payment in Medicare by passing MACRA and exercising oversight authority to help facilitate implementation. We hope these comments will help Congress and the administration improve the QPP, align it with congressional intent in MACRA, and ensure a successful transition to a new Medicare payment system centered around high-value care. 

Reduce Medicare quality reporting documentation requirements

Group practices are now 81 days into a 365-day quality reporting period without the most basic information regarding whether they are eligible to participate in MIPS this year. This information gap is exacerbated by the burden of full-year quality reporting with little evidence of care improvement compared to a 90-day reporting period. This is unnecessarily burdensome for those reporting providers who will ultimately be deemed excluded from the program and moreover, at odds with Congress’ goal of reducing the cost of healthcare, as full-year quality measure tracking and reporting is estimated to cost medical groups close to $700 million in 2018.  

Based on a study of MGMA member practices, this cost estimate may be low.   Our research determined 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. Most of the time spent on quality reporting consists of “entering information into the medical record only for the purposes of reporting for quality measures from external entities.”

We urge this Subcommittee to provide immediate relief by working with CMS to shorten the current MIPS quality reporting period to 90 consecutive days. There is precedent for this action. In response to the introduction of legislation  to shorten the Meaningful Use EHR reporting period from a full year to three months, CMS retroactively amended its regulations to relieve the onerous reporting burden in 2014, 2015 and 2016. Congress should consider using its influence in the same way to relieve the quality reporting burden in MIPS.   

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