In comments submitted to the Centers for Medicare & Medicaid Services (CMS) yesterday, the National Partnership for Women & Families praised the proposed Medicare Access and CHIP Reauthorization Act (MACRA) rule for its potential to strengthen the delivery of health care for Medicare beneficiaries and promote high-value care.

“MACRA’s Quality Payment Program has the potential to be a catalyst for changing how our nation pays for health care and moving us away from fee-for-service and toward value-based payment. But to be successful, CMS and participating providers must give as much attention to improving the delivery of care as they do to reducing spending,” said National Partnership President Debra L. Ness. “As it finalizes the MACRA rule, CMS can consistently support this balance by prioritizing high-quality measures, robust use of health information technology, continuous practice improvement and meaningful patient and family engagement.”

In its comments, the National Partnership acknowledged the potential of MACRA’s Quality Payment Program, particularly Advanced Alternative Payment Models (Advanced APMs), to transform health care payment, but noted, “Ultimately, APMs should enable us to achieve all three tenets of the Triple Aim – better health outcomes, better experience of care, and lower costs – but they can do so only if they engage and meet the needs of the patients they serve and improve how care is delivered.” To ensure that Advanced APMs ultimately deliver on this vision, the National Partnership encourages CMS to add an additional criterion for qualification that would require APMs to demonstrate that their payment strategies promote and support coordinated, effective patient- and family-centered care models. The letter specifically urges CMS to extend the Medical Home care delivery requirements to all Advanced APMs.

The National Partnership’s MACRA comments include specific recommendations to CMS to help ensure the Quality Payment Program under MACRA fully supports patient- and family-centered care by:

• Within the quality performance category of the Merit-Based Incentive Payment System (MIPS), prioritizing the use and development of quality measures that are meaningful to patients and consumers, such as patient-reported outcomes measures (PROMs) and measures of care coordination, patient experience, patient safety, resource use and efficiency.
• Within the clinical practice improvement activities (CPIAs) performance category of MIPS, improving the structure and reporting on activities by:
• Providing greater specificity on CPIAs, particularly for the Beneficiary Engagement and Care Coordination categories;
• Consolidating similar activities to create CPIAs that more comprehensively address clinical areas of focus; and
• Aligning quality measures with CPIAs to promote data-driven improvement.
• Within the advancing care information performance category of MIPS, retiring the “one patient” requirement, and instead increasing the threshold to five percent of all patients in 2019. Keeping the “one patient” threshold would undermine CMS’ commitment to make patients and family caregivers true and equal partners in improving health through shared information and shared decision-making.
• Within the Advanced APM section of the Quality Payment Program, requiring Medical Home Models seeking to qualify as Advanced APMs to meet all seven of the domains listed in the proposed rule’s definition of a Medical Home Model, including planned coordination of chronic and preventive care; patient access and continuity of care; risk-stratified care management; coordination of care across the medical neighborhood; patient and caregiver engagement; shared decision-making; and payment arrangements in addition to, or substituting for, fee-for-service.
• Adding key functionalities to the definition of certified electronic health record technology (CEHRT) to help engage patients and coordinate and evaluate care – including incorporation of social, psychological and behavioral data; care plans; and accessibility-centered requirements.

“The MACRA rule CMS has proposed is a catalytic and encouraging first step in driving the health care system transformation our country urgently needs,” Ness added. “It moves the country away from payment models that reward volume rather than quality or value. We urge agency leaders to adopt these recommendations, which will advance high-quality, patient- and family-centered care for millions of people.”

The National Partnership’s comments can be found here.