HFMA Comments on CMS's MACRA Proposed Rule (CMS 5517-P)
HFMA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the MACRA Proposed Rule published in the May 9, 2016, Federal Register.
HFMA would like to commend CMS for its thorough analysis and discussion of the myriad Medicare physician reimbursement decisions addressed in the MACRA Proposed Rule. While we support the transition to value-based payment, our members are deeply concerned about the timeline against which CMS is attempting to implement MACRA. The sheer scale of the changes contemplated to physician payments by MACRA the potential for unforeseen adverse consequences on both patients and providers is significant. Therefore we ask for a one year delay of the rule’s provisions. Beyond general concerns about the timing HFMA would like to offer suggestions for improving the following key areas in the rule: 1) Merit-Based Incentive Program 2) Advanced Alternative Payment Model Incentive 3) Other Payer AAPM 4) Lack of Accompanying Proposed Changes to the Fraud and Abuse Regulations.