WHA Submits Comments on MACRA Proposed Rule

July 01, 2016

The need for flexibility as well as administrative ease were key themes of proposed comments submitted June 27 by WHA to the Centers for Medicare and Medicaid Services (CMS) in a letter on their proposed rule to implement the Medicare Access and CHIP Reauthorization Act (MACRA). The implementation timeline, need for a focus on rural areas and suggestions for additional alternative payment model (APM) options prompted WHA to encourage CMS to adopt a thoughtful and accommodating approach to implementing what they are now calling the Quality Payment Program.

"Wisconsin is home to very innovative health systems which, by many national measures, provide very high quality health care," said WHA President/CEO Eric Borgerding in the comment letter. "WHA strongly supports payment systems that reward value and believes value-based payment policies can drive better quality, lower cost of care and can reduce overall costs for health care programs. Such programs must be thoughtfully implemented, recognize administrative burdens and complexities and be highly accurate in order to drive improvement.” 


WHA’s comments are consistent with feedback garnered from members over the past months. In addition, Borgerding and Mark Thompson, MD, Monroe Clinic’s chief medical officer, had the opportunity to discuss MACRA implementation directly with CMS Director Andy Slavitt, at an invitation-only meeting held in Chicago June 13. (See Valued Voice story

In its written comments, WHA encourages CMS to seek alignment between hospital-based measures and physician measures. In Wisconsin, as many as 70 percent of physicians are now estimated to be employed by a hospital or health system. Wisconsin has tremendous integrated care, where incentives between providers and hospitals are aligned. “Measures that are relevant and aligned for both physicians and hospitals will be a key strategy for driving meaningful improvement in quality and cost,” Borgerding said. 

WHA also encourages alignment across payers as a way to drive efficiency, achieve better patient outcomes, and reduce administrative burden. Finally, WHA’s comments included several recommendations around the implementation of the electronic health record provisions proposed by CMS. WHA noted that it shares CMS’s belief that exchange of health information can help providers improve quality and efficiency of care, and that its comments are intended to help minimize administrative burden on providers in complying with program requirements. 

WHA’s comment letter can be found here.

This story originally appeared in the July 01, 2016 edition of WHA Newsletter