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News & Press: Government Affairs News

AAOE Submits Comments on MACRA Implementation

Friday, April 6, 2018   (0 Comments)
Posted by: Bradley Coffey, MA, AAOE Government Affairs
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Indianapolis, IN - The American Alliance of Orthopaedic Executives (AAOE) submitted comments to the House Committee on Ways and Means on Wednesday, April 4 concerning the implementation of the Medicare Access and CHIP Reauthorization Act of 2015. In the letter, AAOE thanked the Committee for its recent revisions to the Merit-based Incentive Payment System (MIPS) in the Bipartisan Budget Act of 2018 but urged the Committee to take greater steps to make the program successful. AAOE's recommendations included:

  • Repeal the budget neutral requirement of the program;
  • Encourage greater emphasis in MIPS on Quality Measurement and Advancing Care Information;
  • Implement an exemption for small practices (15 or fewer physicians) from ACI category provided they report their quality measures electronically (registry, EHR, QCDR);
  • Provide more opportunities for specialists to redesign care models through Advanced APMs to produce enhanced patient outcomes;
  • Indefinite 90 day reporting period for MIPS;
  • Allow group practices larger than 10 providers to join virtual groups;
  • Modify the Stark Law to accommodate value-based care design;
  • Encourage physician leadership of value-based models;
  • Maintain the program's focus on electronic reporting;
  • Include an outpatient total knee arthroplasty clinical episode in BPCI Advanced; and,
  • Repeal the ban on physician-owned hospitals.

AAOE also opposed a recent proposal to replace the MIPS program with another value-based model. The Advocacy Council explains its thinking in its comments:

Our members have spent thousands, if not millions of dollars learning MIPS, changing workflows, and investing in equipment to accommodate the requirements of MIPS. To repeal and replace the MIPS program just as our members have become comfortable with the requirements will have made these investments nothing more than exercises in compliance rather than a coordinated effort in transforming care. Additionally, we believe that calling the replacement a “voluntary value program” is a misnomer. Discussion among commissioners about this replacement program indicated that all providers could see their reimbursements cut up to 7%. For an average orthopaedic practice with net collections at the median of national benchmarks, this would translate to an annual loss of $260,168 but cuts to reimbursements would range between a high of $852,975 to a low of $67,065 per practice. According to MedPACs discussions, providers participating in the “voluntary value program” would be able to earn that money back based on reporting via claims data, providers not participating in the program would lose that 7%. 

For questions about AAOE's comments or 2018 policy priorities, please contact AAOE's Manager of Government Affairs, Bradley Coffey, MA at or 317-749-0629.

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