ASNC, Cardiovascular Societies Comment on MACRA Proposed Rule
In two sets of comments delivered to the Centers for Medicare & Medicaid Services (CMS), ASNC urged changes to the proposed rule for implementation of the Medicare Access and Chip Reauthorization of 2015 (MACRA). The sustainable growth rate (SGR) was replaced with MACRA, which includes the new Merit-Based Incentive Payment System (MIPS) and new payment structure available for Alternative Payment Models (APMs). For details about the MACRA proposed rule, visit the ASNC.org MACRA Resource Center.Five Societies Speak as One
ASNC joined with the American Society of Echocardiography (ASE), Society for Cardiovascular Angiography and Interventions (SCAI), Society of Cardiovascular Computed Tomography (SCCT) and the Society for Cardiovascular Magnetic Resonance (SCMR) to recommend that MACRA implementation should—
- Include lab accreditation as a Clinical Practice Improvement Activity,
- Refrain from using episode group measures that have not previously been used in quality payment programs in the cost/resource use performance category, and
- Launch episode measurement with a focus on discrete procedures for which episode windows and attribution are more easily defined.
ASNC Speaks for Nuclear Cardiology
Commenting on behalf of the Nuclear Cardiology community, ASNC also delivered its own comments on MACRA to CMS. ASNC noted that it welcomes the proposed rule's provisions for use of Qualified Clinical Data Registries (QCDRs; such as ASNC's ImageGuide Registry) while advising modifications to streamline requirements and make registry reporting more user-friendly. ASNC also praised the proposed rule's abandonment of the “all-or-nothing” methods used in previous quality reporting and the reduction in required measures to cover a specific number of National Quality Domains. ASNC urged CMS to modify the MACRA implementation plan to include—
- Greater flexibility for physicians using a QCDR to report in the Quality performance category,
- More robust attribution methods,
- Use of episode groups only when they have been previously included in Quality and Resource Use Reports (QRURs), and
- Imaging lab accreditation on the list of Clinical Practice Improvement Activities.