MACRA Draft Plan Is Short on Details

On December 18, 2015, CMS released its draft plan for developing the quality measures that will be used within both the MIPS and APM components of MACRA. The purpose of this draft plan and the mandate for the Secretary of HHS, at least theoretically, is to:

  • Address how measures used by private payors and integrated delivery systems could be incorporated into Title XVIII (i.e., Medicare).
  • Describe how coordination across organizations developing such measures might occur.
  • Take into account how clinical best practices and clinical practice guidelines should be used in the development of quality measures.

What’s clear is that behind CMS’s high hopes for MACRA are a lot of loose ends. Stakeholders who have been closely monitoring the unfolding of MACRA’s details might have anticipated valuable insights to help them prepare for the implementation of these measures in 2019, just 3 years away. Unfortunately, the draft plan offers little (if anything) that is new and useful.

Instead, despite its length of 61 pages, the document deals only in generalities.  For example, it includes a timeline containing key milestones between now and the implementation date – most of which were already established in the legislation – without revealing specifics around the activities associated with those milestones.  There is a rather extensive discussion of CMS’s strategic vision for measure development priorities that merely hints at how measures will be selected (e.g., General Principle #10 is to “focus on what is best for patients and caregivers for each decision made during the development life cycle”).

The approach to achieving that vision is communicated through similarly vague and aspirational language such as “CMS will leverage multi-stakeholder groups to identify the issues related to the development of measures that can be applied across payers and delivery systems.” No word on how this leverage will actually occur, through what process, or when results are to be expected.

CMS must release its final plan on May 1, 2016, and will be receiving public commentary on the draft plan until March 1. Provider organizations should familiarize themselves with the plan and make their voices heard through professional associations, letters to Congress, and other appropriate means. In the meantime, ECG will continue to monitor the rollout of MACRA and will provide updates through blog posts and other channels.

This entry was posted in Accountable Care Organization, Healthcare Reform, Healthcare Reimbursement, Legislative & Regulatory Issues, PCMH, Physician Compensation, Population Health Management, Strategic Planning and tagged , , , , , , , , by Dave Wofford. Bookmark the permalink.

About Dave Wofford

For almost 20 years, Dave has focused on improving performance and achieving alignment between hospitals, physicians, and other entities. Dave’s clients appreciate his knowledge of the issues related to hospital/physician relationships and affiliations, as well as his understanding of the perspective and value that each party brings. This, in turn, allows him to help parties reach sustainable arrangements. As providers seek opportunities for clinical affiliation and collaboration in an era of shrinking revenue sources and increased competition, Dave works closely with hospitals and medical groups on matters such as physician compensation plan redesign, strategic planning, and the negotiation and development of professional services arrangements. He consults to hospitals and physicians on issues concerning operations, business planning, strategic alignment, and in particular, professional revenue cycle performance turnaround. Recently Dave worked with Children’s Hospital Los Angeles Medical Group, an organization consisting of approximately 500 professionals. He led an effort to improve the group’s revenue cycle performance, which resulted in significant reductions in accounts receivable and IT vendor fees, positioning the organization for enhanced ongoing collections. Prior to joining ECG, Dave served as an officer in the U.S. Army for 8 years, and today his clients value the leadership qualities honed during important international assignments.

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