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URAC Recommends Medicare Align Incentives to Encourage Flexible, Sustainable Improvement

Wednesday, June 29th, 2016

URAC submitted comments to the Centers for Medicare and Medicaid Services (CMS) about how the government might improve its proposed rule to implement health care reimbursements as authorized by the Medicare Access and CHIP Reauthorization Act (MACRA).

“We believe that flexibility, sustainability, and quality improvement are not mutually exclusive ideas,” said URAC President and CEO Kylanne Green. “URAC believes that CMS could further promote and more effectively measure quality over time through the creation of a minimal framework that highlights the alignment of Clinical Practice Improvement Activities with the PCMH model for physicians.”

MACRA, signed into law in 2015, changes how Medicare reimburses providers serving Medicare beneficiaries. The almost 1,000-page proposed rule – which, when finalized, will define how MACRA is enforced – was released by CMS in late April. The rule specifically describes new Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) options. MACRA is scheduled to go into effect on January 1, 2019. CMS estimates it will affect 700,000 physicians.

URAC suggested MACRA-created Quality and Clinical Practice Improvement Activities (CPIA) options available through MIPS “be weighted based on complexity and costs associated with delivering a service so that the most challenging services are weighted more heavily.” Providing an incentive for improvement is recommended as “a better approach for [physician practice] transformation than the proposed ‘a la carte’ approach.”

For example, the government could more closely set its practice improvement goals to the established patient centered medical home (PCMH) model of coordinating delivery of care and increasing the involvement of the patient in decision-making. In the comments, it was noted: “Such an approach allows practices to more fully understand the activities associated with a PCMH and potentially offset the costs associated with transformation” and “allow physicians to better understand the activities associated with the PCMH model and decide how to best deliver care under MIPS.”

URAC is listed in the proposed rule as an organization recognized to certify PCMHs for their performance and adherence to performance benchmarks under the CPIA category of MIPS.

Additionally, URAC recommended “align[ing] measures domains with relevant [quality] subcategories” to “encourage physician selection of [performance] measures that would allow CMS to evaluate the potential impact of activities on quality.” Both this and an embrace of the PCMH model are considered vital for practices to eventually meet the expectations of CMS’s APM – the next step along the continuum toward practices accepting increased financial risk and providing more coordination of care.

CMS was also encouraged “to expand virtual [practice] groups” beyond the proposed reporting program because they “hold the promise to promote the adoption of activities that enhance care coordination and improve quality outcomes that are often out of reach for small practices due to limited resources.” Noting such collaboration could raise anti-trust concerns, URAC encouraged CMS to utilize existing national standards to promote the adoption and growth of virtual groups. URAC’s Clinical Integration Accreditation provides validated standards and is aligned with Federal Trade Commission guidelines to support such activity.

The complete comment can be viewed by clicking here.

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For 25 years, URAC has been the independent leader in promoting health care quality through accreditation, education, and measurement. URAC offers a wide range of quality benchmarking programs that reflect the latest changes in health care and provide a symbol of excellence for organizations to showcase their validated commitment to quality and accountability. URAC’s evidence-based measures and standards are developed through inclusive engagement with a broad range of stakeholders committed to improving the quality of health care.

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