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June 24, 2016

AAOS Comments on MACRA Proposed Rule

Washington, DC—Today, the American Association of Orthopaedic Surgeons (AAOS) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule for the physician reimbursement framework required under the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015. The new framework—which replaces the flawed Sustainable Growth Rate (SGR) formula—is called the Quality Payment Program (QPP) and includes two pathways: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). While AAOS expressed support for the efforts to reduce administrative burden on clinicians and introduce greater flexibility in reporting requirements, the comments outlined a number of areas of concern, including performance year timing, access to data, and the potentially negative impact on smaller or solo practices.
"AAOS is pleased with the new and more flexible reporting requirements, which streamlines the multiple Medicare physician quality reporting programs into a single system,” the comments stated. “However, given that these regulations will not be finalized until the fall of 2016, it will be burdensome, if not impossible, for physicians to get ready for the first performance year of 2017."
Specific to the Advancing Care Information (ACI) category under MIPS (previously the “meaningful use” program), AAOS noted that the reduction of required measures is a positive step, yet interoperability and infrastructure readiness remain obstacles to successful reporting. AAOS expressed further concern that there continues to be a pass/fail element in the base performance score and that the reporting period is expanded to a full calendar year, stating that “continuing a ‘pass/fail’ scoring contradicts the overall aim of removing the ‘all or nothing’ approach” and the “expansion of the 90-day reporting period to a full calendar year is problematic for new participants.”
Finally, AAOS expressed disappointment that the proposed rule does not list either the Bundled Payments for Care Improvement (BPCI) models or the Comprehensive Care for Joint Replacement Model (CJR) as Advanced APMs. The CJR model, which is mandatory in 67 areas in the U.S., was initiated in April of 2016 and its exclusion in the proposed rule is inconsistent with the intent of the MACRA legislation and the goals spelled out by CMS. Because of the model’s scope and its inclusion of quality measures, advancing care information requirements, clinical improvement activities, and risk bearing requirements, the AAOS believes that the CJR model should already qualify as an Advanced APM. However, AAOS pointed to its comments submitted in response to the CJR proposed rule for redesign options, including switching to physician – rather than hospital – leadership. Further, AAOS emphasized the restrictive requirements to qualify for Advanced APM status and suggested CMS reconsider the definition of nominal total risk.
“AAOS is thankful for the opportunity to comment on this proposed rule and looks forward to engaging with CMS to ensure MACRA provisions ultimately improve the care of musculoskeletal patients,” said AAOS President Gerald R. Williams, Jr., MD. “Patient care is of the utmost importance. While many provisions in the proposed rule are improvements over the current system, there are a number of steps that would better protect specialty physicians along with small and solo practices so that Medicare patients have access to the timely, high-quality, affordable specialty care that they need. We are hopeful that CMS will take seriously these concerns and we will continue working to improve care delivery for all Americans.”

For further information, visit or read the AAOS comments to CMS.

Follow the AAOS Office of Government Relations on Twitter: @AAOSAdvocacy
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