Premier : Statement on the Proposed Regulation to Implement the Medicare Access and CHIP Reauthorization -Act of 2015 (MACRA)
April 28, 2016 at 10:55 am EDT
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Members of the Premier alliance believe that the Centers for Medicare & Medicaid Services (CMS) has made a significant mistake by not including any bundled payment or Track 1 Medicare Shared Savings Program (MSSP) ACOs as qualifying advanced payment models (APMs) under MACRA.
Rather than rejecting bundled payment programs, we believe CMS should focus on ways to alter the bundled payment programs to demonstrate use of certified EHR technology and align measures with other APMs. We also believe CMS seriously erred in excluding Track 1 MSSP ACOs in the APMs for failing to meet the more than 'nominal risk' financial requirement. As we have learned through members in our population health management collaborative, these programs require providers to not only forego revenue through a lower volume of services, but also invest millions of dollars in redesigning care through new technologies, data analytics, additional staff, etc. We think most businessmen would call that more than nominal risk, yet CMS chose to define it as only cases where there is risk to the government.
In not recognizing Track 1 ACOs and bundled payment options as APMs, the proposed rule could have the unintended consequence of waiving physicians off the APM path in favor of fee-for-service. This undermines the very intent of MACRA to incent providers to move to value-based payment models.
-Blair Childs, Senior Vice President of Public Affairs, Premier Inc.
Premier Inc. issued this content on 27 April 2016 and is solely responsible for the information contained herein. Distributed by Public, unedited and unaltered, on 28 April 2016 14:54:15 UTC
Original Document: https://www.premierinc.com/premier-statement-proposed-regulation-implement-medicare-access-chip-reauthorization-act-2015-macra/
Premier, Inc. is a healthcare improvement company uniting an alliance of approximately 4,350 United States hospitals and health systems and approximately 300,000 other providers and organizations. It operates through two segments: Supply Chain Services and Performance Services. The Supply Chain Services segment includes the Companyâs group purchasing organizations (GPO), supply chain co-management, purchased services, and direct sourcing activities. The Performance Services segment consists of three sub-brands, which include PINC AI, the Companyâs technology and services platform; Contigo Health, the Companyâs direct-to-employer business; and Remitra, the Companyâs digital invoicing and payables business. It delivers technology-enabled platform that offers critical supply chain services, clinical, financial, operational and value-based care software as a service (SaaS) as well as clinical and enterprise analytics licenses, consulting services, and third-party administrator services.