The American Medical Association (AMA) submitted comprehensive comments today to the Centers for Medicare & Medicaid Services (CMS) and outlined recommended changes to the proposed rule on Medicare payment and delivery reform, as created by the Medicare Access and CHIP Reauthorization Act (MACRA). The AMA believes that CMS has proposed a number of important improvements in the program, but the nation's largest physician organization continues to urge the agency to seek ways to simplify and further streamline the program and create more opportunities for physicians to participate in new value-based payment options. The AMA proposed specific revisions to the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) option, both of which were created by MACRA.

In its letter to CMS, the AMA outlines steps the agency should take to ensure a smooth transition to the new payment system so physicians have time to adopt and invest in practices that can enhance patient care and constrain costs. The AMA also proposed steps the agency should take to promote physician-led APMs. In MIPS, the AMA applauded CMS's response to the concerns of small and rural practices, including an option for small groups and solo practitioners to form virtual groups.

"When physicians are asked to move to a new program, we expect some bumps along the way. CMS has been a good partner in smoothing out the bumps but the program still needs to be more understandable and less burdensome. The complexity is an obstacle to the goal of promoting innovative approaches to encourage higher value care. We applaud CMS' decision to allow for another transition year for MIPS, recognizing the challenges physicians face both bureaucratic and technological. The willingness to compromise will help physicians and patients alike," said AMA President David O. Barbe, M.D.

Technological and administrative obstacles are practical concerns that affect physicians daily. Nearly half a physician's office day is now filled by data entry into electronic medical records (EHRs) and administrative desk work, according to a time-motion study conducted by the AMA and Dartmouth-Hitchcock health care system. As administrative duties cut into patient time, the AMA wants to ensure that new programs do not add significantly to the clerical burden that physicians face.

The AMA recently unveiled new tools to encourage and simplify participation in the program, including a customizable MIPS Action Plan that will help physicians pursue the right course of action for their practice, take recommended steps to meet program requirements, and measure their performance against important milestones. The AMA also released a short video, entitled "One patient, one measure, no penalty: How to avoid a Medicare payment penalty with basic reporting." AMA's full suite of resources to help physicians transition is available on the AMA website.

The new resources come on the heels of a recent survey conducted by the AMA and KPMG that shows an overwhelming majority of physicians are unprepared to participate successfully in MIPS, despite the transitional flexibility provided for 2017.