AMGA to CMS: Limit MACRA transition, develop MSSP ACO Track 1+

In its comments to CMS on the final Medicare Access and CHIP Reauthorization Act (MACRA) rule, the American Medical Group Association (AMGA) asked the agency to limit the transition to new payment tracks to only one year and develop a new two-sided risk model in the Medicare Shared Savings Program (MSSP).

CMS has defined 2017 as a “transition year” for MACRA’s Quality Payment Program, offering practices the opportunity to pick their pace by allowing partial participation while still avoiding a negative adjustment in 2019. The response from medical groups was almost uniformly positive, and CMS has said it envisions 2018 to be similarly “transitional in nature.”

AMGA, however, wants 2018 to be a full reporting year for the Merit-based Incentive Payment System (MIPS), arguing that too long of an “on-ramp” is unfair to practices that have invested in new technology and care coordination.

“The agency's decision to define 2017 as a ‘transition year’ is a step backward as it penalizes providers that have taken steps to improve care and population health and reduce spending growth in order to effectively subsidize providers that have not yet to date chosen to do so,” wrote AMGA President and CEO Donald Fisher, PhD. “AMGA hopes CMS will fully implement the MIPS program in performance year 2018.”

AMGA said while the longer transition limits how many practices will receive a negative adjustment, it will also prevent many from earning the maximum 4 percent positive adjustment in 2019.

For the advanced Alternative Payment Models (APMs) track, AGMA applauded CMS’ commitment to develop a new option for accountable care organizations in MSSP. The so-called “MSSP ACO Track 1+” would include less financial risk than Tracks 2 and 3 but enough to qualify as an APM, opening up more opportunities for practices to earn the 5 percent APM bonus.

AMGA recommended Track 1+ include the following:

• Allows all current ACO participants.
• Allows for all current ACO program and ACO demo participants the ability to participate in Track 1+ in any performance year.
• Allows for indefinite participation or participation beyond six years or two three-year agreement periods.
• Employs regional financial benchmarking.
• Offers greater incentives or a higher earned shared savings percent than Track 1.
• Allows for either preliminary prospective or prospective beneficiary assignment and allows Track 1+ participants MSR/MLR flexibility.
• Allows for beneficiary attestation.
• Allows for risk adjustment for health status for the continuously assigned.
• Offers participants the ability to apply for payment waivers including home health, skilled nursing and telehealth.

Currently, only MSSP Tracks 2 and 3 are eligible APMs, with the undefined Track 1+ allowing participants to receive the bonus payment in 2018.