In a public comment submitted to the Centers for Medicare and Medicaid Services (CMS), URAC suggested any plan for “virtual groups” comprised of small and solo physician practices encourage collaboration and create relationships that may “evolve into a commercially sustainable venture capable of delivering quality care regardless of payer.”
URAC, a nonprofit, independent healthcare accreditation company, also called for CMS virtual group guidelines to encourage practices to self-select and pool resources for aligning clinical standards, sharing data, and coordinating care. CMS sought feedback from stakeholders regarding implementation of virtual groups as part of the Quality Payment Program (QPP) of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). URAC’s response to the CMS call for comment on QPP implementation was sent on December 19.
“When two or more practices join together, they are effectively creating a network. Collaboration shouldn’t end with compliance reporting when economies of scale and other benefits can be achieved through these alliances,” said URAC President and CEO Kylanne Green. “The best solutions are often local solutions found within the community. With the right support, CMS can create an environment where virtual groups bring together members of the medical community to promote local innovation and improved, sustainable performance.”
MACRA will determine future physician reimbursement for the treatment of Medicare beneficiaries. URAC’s comment focuses on the CMS virtual group plan – scheduled to begin in 2018 – allowing practices of ten members or less and solo practitioners to join together to submit composite scores and meet quality measurement requirements.
In the comment, URAC wrote: “We encourage CMS to establish a process by which virtual groups can achieve economies of scale for activities beyond compliance. If implemented with an eye toward the future, what begins as a program to meet government requirements may evolve into a commercially sustainable venture capable of delivering quality care regardless of payer… To realize the full potential of virtual groups, CMS should encourage virtual groups to share clinical guidelines, promote clinician responsibility, and share performance data among its participating providers. When considering standards for virtual group participation, CMS should pay special attention to any opportunity to integrate behavioral health practices with primary care.”
URAC’s comment cited the work of national accrediting organizations to help promote virtual group collaboration. For example, URAC’s standards for Clinical Integration Accreditation contain quality standards for shared clinical guidelines, data-sharing techniques, and measures reporting that can “ensure effective, shared responsibility among members.” The comment also noted that CMS “must protect against anti-trust issues that may arise from physician collaboration” – another factor addressed by URAC’s quality standards.
“URAC’s Clinical Integration Accreditation was developed by key stakeholders and publicly vetted to incentivize sustainable growth in a value-based reimbursement environment,” said Green. “These standards promote best practices and troubleshoot common problems associated with practice collaboration. It can aid CMS in promoting the expanded development of virtual groups beyond just quality reporting.”
URAC’s full comment to CMS is available on the URAC website.