October 14, 2016
WASHINGTON, DC— The NCQA team of policy experts have dissected the details in the MACRA final rule since its release this morning. Here is our early reaction and response.
“NCQA commends CMS for maintaining its support for NCQA Patient-Centered Medical Homes (PCMHs) and Patient-Centered Specialty Practices (PCSPs),” said NCQA Director of Federal Affairs Paul Cotton. “Patient-centered care is the key to success for clinicians in all of the categories that MACRA will measure and use to adjust payments.”
As a measure developer, NCQA is disappointed in the relaxed reporting requirements and the lack of rigorous quality measure criteria.
“We appreciate the need to ease the initial reporting requirements for this historic move to paying clinicians for the value rather than simply the volume of care they deliver,” said Cotton. “However, this will result in a less robust assessment of quality on which payments are based, and we encourage CMS to revisit and raise standards for MACRA in future rule making.”
Other Early Reaction
- Behavioral Health. We are pleased that the MACRA final rule prioritizes behavioral health by including more behavioral health measures. Behavioral conditions are substantially undertreated and strongly associated with greater use of other health care services and higher costs. When left untreated, it could lead to needless suffering and higher costs for other medical conditions. The additional measures included in the final rule will encourage more care coordination between behavioral and physical health providers.
- Small Practices. We are encouraged by CMS’ provisions that ease the burden on small practices. Ensuring the viability of these practices will be critical for protecting access in certain parts of the country and ensure that MACRA works for all clinicians, not just those in more organized systems.
- Electronic Reporting. The final rule includes bonus points for electronic reporting. This will encourage our health care system to work toward more and better outcome measurement. We hope this encourages electronic health record vendors to build systems that derive measures from natural clinical workflows to minimize reporting burden. The success of electronic reporting will be contingent upon the ability of systems to provide accurate and reliable quality measure results. We remain concerned about the current tools available to certify validity of measure results and encourage you to consider additional certifications such as NCQA’s eMeasure certification. Industry leaders such as HIMSS and Premier have consistently stated that NCQA certification is more robust and rigorous than existing ONC processes.
NCQA looks forward to exploring the final rule and working with CMS on further updates.