20 Dec Task Force Provides Input on CMS Final Rule
The HCTTF supports the policies of MACRA and moving Medicare payment for physician services to a value-based formula that focuses on quality, resource use, clinical practice improvement, and meaningful use of certified EHR technology under the Medicare Incentive Payment System. As a major proponent of value-based care furnished through alternate payment models, the HCTTF also supports the opportunity for qualifying physicians to benefit from participating in Advanced APMs or MIPS APMs.
Our comments primarily focus on the remaining provisions open for comment addressing advanced APMs and MIPS APMs. We urge CMS to interpret Advanced APMs and MIPS APMs in ways that support the maturation of ongoing value-based payment models occurring in existing APMs. We also urge CMS to seek public comment on any provisions of the final rule that are to be finalized, in more detail, in future years.
Task Force Response Summary
1. Advanced APM Revenue-Based Nominal Amount Standard. The Task Force supports the adoption of a revenue-based standard as an alternative to the total cost of care standard. The HCTTF does not support the application of a revenue-based standard to a large entity in lieu of the specific sub-entity for which the standard would have implications.
2. Other Payer Advanced APM Financial Risk Criteria. The Task Force does not support exceedingly stringent risk criteria for other payers
3. Medical Home Model Financial Risk Criteria. The Task Force believes that organizations enrolled in the CPC+ program should not be limited in their ability to qualify as Advanced APMs based on a size threshold. The Task Force supports the assessment of all CPC+ organizations using the Medical Home Model Financial Risk Criteria, regardless of size.
4. ACO Track 1+ Model. We support the creation of a new two-sided risk model that would provide an intermediate step along the continuum to fully mature two-sided risk models for both hospital and physician-led ACOs.
5. QP Determination. For clinicians who are participating in models that qualify as MIPS APMs, but will not meet the Advanced APM threshold criteria, the Task Force supports the addition of a fourth “snapshot” on December 31 of the performance year.
6. Notification of QP Determination. The HCTTF urges CMS to engage with stakeholders in industry before issuing subregulatory guidance regarding the notification of QP determinations.
7. MIPS APMs. We urge CMS to allow facility-led APM entities to qualify as APMs, and to revise the requirement so that the APM entity includes one or more MIPS eligible clinicians on either a Participation List or an Affiliated Providers List. The first criterion could be revised to read as “participates in an APM sponsored by CMS.”
8. Virtual Entity Reporting Under MIPS. The Task Force asks that CMS allow the flexibility for organizations to define their own TINs for group reporting.
Letter submitted on December 19, 2016