ASA submits comments in response to CMS's RFI on MACRA

The American Society of Anesthesiologists has submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the agency’s request for information on implantation of the  Merit-based Incentive Payment System (MIPS) and promotion of Alternative Payment Models (APM) within the Medicare Access and CHIP Reauthorization Act (MACRA).  ASA discussed elements that need to be in place in order for physician anesthesiologists to successfully participate in these programs. In the comments, ASA encompass all the elements within MIPS (quality, resource use, meaningful use of EHR and clinical practice improvement activities) as well as how the Perioperative Surgical Home (PSH) can fit into an APM.

Key points within the comments include:

•  Alternative Payment Models:
o  ASA emphasized that APMs must be developed in a collaborative manner and urged CMS to use all available resources when developing and evaluating APMs. ASA specifically notes the Physician-Focused Payment Model Technical Advisory Committee and the expertise already present within many specialty societies.   The Perioperative Surgical Home should have a place in any procedure-based APM that includes a procedure that requires anesthesia care.

•   MIPS:
o  ASA said there must be flexibility in weighting performance categories.  ASA strongly supported dropping a category when there is no opportunity for an Eligible Professional (EP) or specialty to meet criteria and remaining categories should be reweighted.
o   In response to CMS’s request for questions about feedback reports, ASA noted that transparency is key. In comments, ASA stated that CMS needs to provide regular and frequent feedback to all EP’s regardless of the mechanism they use to report performance.

ASA strongly encourages CMS to take all of its comments into consideration when drafting a proposed rule in 2016.  

Read the full letter ASA submitted to CMS.