SHM Submits Comments, Suggestions on MACRA Rule to CMS

Comments Seek to Ensure Hospitalists Can Participate in Payment Pathway of Their Choosing, Stresses Fair and Accurate Assessment

The Society of Hospital Medicine (SHM) submitted comments on Monday, June 27 to the Centers for Medicare and Medicaid Services (CMS) on the Medicare Access and CHIP Reauthorization Act (MACRA), which establishes new ways to reimburse providers caring for Medicare and Medicaid beneficiaries. Since hospitalists provide care for millions of hospitalized patients each year, many of whom are Medicare and Medicaid beneficiaries, the implementation of MACRA is poised to have an extensive impact on hospitalists. SHM issued comments to ensure that hospitalists and other providers have a realistic option in choosing between the payment pathways set up via MACRA, and that providers are fairly and accurately assessed in these programs.

“SHM is advocating from a belief that hospitalists should have the ability to participate in the pathway of their choosing—the MIPS or APMs,” explains Ron Greeno, MD, MHM, President-Elect of SHM and Chair of SHM’s Public Policy Committee. “While we were disappointed that some of CMS’ proposed rules will limit this choice, we look forward to working with CMS and, if necessary, Congress to ensure hospitalists can participate fully and equitably in either pathway.”

In response to the Merit-Based Incentive Payment System (MIPS) pathway of MACRA, SHM highlights the lack of applicable quality measures for hospitalists and the need for relevant and actionable metrics; many of the proposed measures in MIPS are not designed for the inpatient setting or team-based care, which are characteristic of hospitalist practice.

SHM notes that CMS should ensure that hospitalists, who are super-users of hospital electronic health record (EHR) systems, are not penalized by outpatient, physician-level EHR requirements set forth under MACRA’s retooling of the Meaningful Use program. SHM also urges CMS to award points for the team-based and systems-oriented quality improvement work of hospital medicine groups in the new Clinical Practice Improvement Activities category.

In commentary on the Alternative Payment Models (APMs) pathway, SHM expresses concern that the proposed rule will afford very few clinicians with a realistic opportunity to participate in an Advanced APM. SHM recommends that CMS interpret “Advanced APMs” in less limiting ways that will neither discourage APM participation nor hinder further innovation. SHM also provides CMS with some ways in which they may include existing APMs in the new MACRA pathway, such as the Bundled Payments for Care Improvement (BCPI) initiative, and calls for more flexibility in the creation of new models.

SHM looks forward to further collaboration with CMS in implementing and refining MACRA to ensure equitable treatment of providers, as well as deliver a higher quality, more efficient healthcare system to patients.