CMS leaders report to Congress on MACRA implementation

On Wednesday, March 21, the House Ways and Means Committee held a hearing on the implementation of the Medicare Access and CHIP Reauthorization Act’s physician payment policies. The committee heard testimony from Demetrios Kouzoukas, principal deputy administrator, and Dr. Kate Goodrich, the chief medical officer for the Centers for Medicare and Medicaid Services (CMS).

April 4, 2018 | Health care

In his opening statement, Mr. Kouzoukas defined value in health care as “putting patients in the driver’s seat,” and described the principles guiding the Administration’s policy approach to value-based care as giving consumers control over their health information, encouraging transparency for both payers and providers, leveraging the power of patients, and reducing administrative burdens so providers can spend more time with patients.

The House committee expressed a range of opinions on the finer points of implementation of Medicare Access and CHIP Reauthorization Act (MACRA), with many noting that CMS’ move towards regulatory relief and flexibility has been beneficial to providers who are challenged by reporting requirements and expenses. Some committee members questioned the CMS officials on the recent decision to pull back mandatory participation in certain payment models such as the Comprehensive Care for Joint Replacement bundled payment, with CMS officials responding that they want as much payment change as possible to occur voluntarily, even as they support hard targets for Medicare payments being value-based.

Throughout the hearing, CMS officials insisted on the administration’s steadfast commitment to system-wide changes under MACRA and moving towards a more value-driven approach to payment. In turn, the committee sought repeated assurances that further experimentation and change to payment models under MACRA will continue.

No traction for MedPAC’s MIPS recommendation

Notably, committee members did not address a recommendation by the Medicare Payment Advisory Commission (MedPAC) to repeal the Merit-based Incentive Payment System (MIPS) under MACRA’s Quality Payment Program (QPP). In its March report to Congress released on March 15, 2018, MedPAC recommended repealing MIPS and replacing it with a voluntary program in fee-for-service Medicare that would provide value payments based on population measures derived from Medicare claims.

Moving ahead

Taken together, we see the Administration moving forward with implementation of MACRA’s QPP with the support of the Congress. In the February 9 budget agreement, Congress included targeted changes to MIPS that generally provide an additional three years of flexibility for CMS to fully implement the program. Notably among the changes, specific provisions give CMS until the 2022 performance year to increase the weight of the MIPS Cost measure to 30 percent and to set the MIPS performance threshold at the mathematic mean or average of MIPS performance scores. In effect, providing greater flexibility to set the performance threshold—the score that CMS uses to determine which clinicians participating in MIPS will receive a negative, neutral or positive payment adjustment—could result in more clinicians receiving smaller positive payment adjustments than would otherwise be the case.

Beyond these changes, at this time there is little indication that Congress will make larger changes to MACRA in the foreseeable future, increasing the need for health care stakeholders to evaluate their plans for MACRA’s QPP moving forward. This is particularly important in light of the January 1, 2019, beginning of the All-Payer Combination Option, in which providers have the opportunity to become Qualifying Participants via their participation in alternative payment models with payers other than Medicare.

This article contains general information only and Deloitte is not, by means of this article, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This article is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor.

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Anne Phelps
Principal | Deloitte Risk and Financial Advisory

US Health Care Regulatory Leader
Deloitte & Touche LLP

Daniel Esquibel
Senior manager | Deloitte Risk and Financial Advisory

Deloitte & Touche LLP

Ethan Joselow
Manager | Deloitte Risk and Financial Advisory

Deloitte & Touche LLP

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