URAC Submits MACRA Comments, Calls for Continued Support of Small Practices and Those in Rural and Underserved Communities

Tuesday, August 22nd, 2017

WASHINGTON, DC – August 22, 2017 – In response to CMS’s 2018 proposed rules for MACRA’s Quality Payment Program (QPP), URAC submitted comments calling for continued support of small practices and those in underserved communities enabling stronger participation in MIPS.

In the comment letter, URAC applauds CMS’s continued recognition that eligible clinicians and practices are in variable conditions of preparedness for QPP reporting. For this reason URAC supports CMS’s continued phased implementation of the quality reporting requirements of the QPP.

Under the proposed rule, URAC continues to be recognized by CMS as an accreditor of Patient Centered Medical Homes (PCMH). A PCMH practice certified by URAC will receive full credit under the Improvement Activities (IA) category of the QPP’s Merit-based Incentive Payment System (MIPS). URAC’s PCMH Certification program was uniquely designed for practices that are small, rural, and those located in underserved communities that may face resource constraints when pursuing patient-centeredness and coordinated care leading to PCMH Certification. URAC’s stepwise approach to certification supports resource allocation overtime and encourages practice transformation in a manner that fits the unique nature of the practice and the community it serves.

As a sign of URAC’s commitment to resource constrained practices, URAC has released its PCMH Certification standards to the public. To learn more and download URAC’s PCMH standards click here.

URAC’s comment letter included a call for CMS to publish the list of all organizations offering PCMH Certification in which a practice would be eligible for full credit under the IA category. This move by CMS would increase transparency and ease confusion among practices. URAC also cautioned CMS against its proposed plan to require 50% of practices operating under one tax-identification-number to be covered by a PCMH’s Certification in order for the practice to receive full-credit under the IA category of MIPS. Since CMS required only one practice in 2017, URAC notes that a major increase in this requirement will be a significant financial burden to practices – especially small practices and those caring for underserved communities. This proposal by CMS would also have a chilling effect on practices pursuing PCMH Certification in the future. As the clear intent of MACRA is the promotion of PCMHs, URAC recommends a phased implementation over several years with the ultimate goal of 100% of practices being covered by a practice’s PCMH Certification. URAC’s recommendation corresponds with CMS’s stated objective to ease the burden placed on practices and matches other areas of the proposed rule where special consideration has been given to small practices that face unique resource constraints.

For the first time CMS proposed to allow small practices, comprised of 10 or fewer practitioners, to form virtual groups for the purposes of reporting under the QPP. URAC believes that virtual groups have the potential to enable small and solo practices to aggregate patients and ease the burden of reporting. URAC supports CMS’s planned approach to implement virtual groups that can form free of arbitrary restrictions imposed by CMS and thus have the greatest opportunity for sustainable, long-term success.

To read URAC’s full comments to CMS in response to the 2018 proposed QPP click here.

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