The American Hospital Association recommended several changes from the proposed requirements of the new Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs) in written testimony submitted to the House Ways and Means Committee.

While the AHA repeatedly stated in the testimony that it supports aspects of the new system, such as reducing the number of measures required for reporting and the move away from an “all or nothing” scoring approach on electronic records, it expressed broad concerns about areas that may put hospital-based physicians at a disadvantage.

First, the association recommended aligning required MIPS measures with the 2015 report from National Academy of Medicine.

“The Vital Signs report recommends 15 'Core Measure' areas, with 39 associated priority measures. These areas represent the current best opportunities to drive better health and better care, based on a comprehensive review of available literature. Each stakeholder would be measured on the areas most relevant to their role in achieving common goals and objectives,” the AHA’s testimony said.

Secondly, AHA asked for hospital-based physicians to be allowed to use their facility’s own quality reporting and pay-for-performance measures within MIPS, pointing out MACRA allows for CMS to develop those kind of participation options.

Risk adjustment was the association’s third recommendation, arguing that caring for complex patients or sociodemographic factors shouldn’t adversely affect providers’ MIPS scores.

“Without risk adjustment, provider performance on most outcome measures reflect differences in the characteristics of patients being served, rather than true differences in the underlying quality of services provided,” the AHA wrote.

Lastly, the association wants changes to the reporting requirements under the technology use measure, known in MIPS as Advancing Care Information (ACI).

“The AHA appreciates the movement toward flexibility in the measures used in the health information exchange and public health reporting. However, we remain concerned that the reporting burden will remain high, “ the association wrote. “In addition, we note that flexibility has not been proposed for other requirements in the ACI performance category that we believe are important to success—the number of measures that a MIPS-eligible clinician would be required to meet, the length of the reporting period in the first reporting year of a new edition of certified EHR, and the readiness of the standards and technology to support successful attainment of the measures.”

In particular, the AHA questioned whether all hospitals could be reasonably comply with information sharing standards in MIPS with current technology and infrastructure.

The association went into less detail on APMs, but criticized CMS for what it calls a “narrow definition of financial risk.” The proposed rule would require APMs to bear more than a nominal financial risk for losses, which AHA argued doesn’t account for the upfront investment made by providers.

“The AHA believes that such a result is undesirable and at odds with the MACRA’s clear goal of rewarding those physicians who have been early adopters of APMs. In addition, this could inhibit physician movement toward APMs, particularly in early years, if physicians cannot engage with existing model participants—which have a head start on building infrastructure and engaging in care redesign—and instead must start from scratch,” the association wrote.