ASA Submits Comments on the MACRA Proposed Rule

Today, the American Society of Anesthesiologists (ASA) submitted a 40-page comment letter in response to the Center for Medicare & Medicaid Services (CMS) proposed Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule. This proposed rule, released by CMS in April, detailed how MACRA might be implemented beginning in 2017. The final rule is expected by November 1, 2016.

The proposed rule implementing this new payment program is extremely complex and, if finalized, will prove challenging for physicians to successfully navigate. Accordingly, as a priority issue, ASA argued that CMS should not sacrifice the care necessary in developing a smart and defensible payment program under MACRA for an aggressive implementation timeline and strongly supported a delay in implementing MACRA until at least July 1, 2017.

ASA provided more than three dozen recommendations to CMS outlining changes that would improve the ability of physician anesthesiologists to successfully participate in the new system. In particular, in recognition of the fact that most physicians are expected to participate initially in the Merit-Based Incentive Payment System (MIPS) – the law’s fee-for-service pathway, ASA proposed a series of changes to simplify the program., including ways CMS can better align the program with the unique practices of physician anesthesiologists. ASA also supported greater recognition of physicians reporting through mechanisms such as ASA’s Qualified Clinical Data Registry (QCDR). ASA also recommended CMS work to expand opportunities for physician anesthesiologists to participate in the Alternative Payment Model (APM) pathway option.  

Read ASA Comments on the MACRA Proposed Rule.

In addition to its own formal comment to CMS, ASA also signed on to complementary communications and statements on the proposed rule from the American Medical Association and the Physician Clinical Registry Coalition. ASA contributed substantial comments in a letter sent by a coalition composed of ASA, the American Academy of Pain Medicine, the American Academy of Physical Medicine and Rehabilitation, the American Society of Interventional Pain Physicians, the American Society of Regional Anesthesia and Pain Medicine, the North American Neuromodulation Society and the Spine Intervention Society.

Please visit the ASA MACRA webpage for additional information. ASA staff are working to provide additional detail in the upcoming weeks and months to assist members in transitioning to MACRA.