Smaller accountable care organization (ACO) officials wrote comments to CMS noting that some provisions of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) could hurt the viability of smaller ACOs.
The proposed rule, MACRA, will split physicians into those paid under the Merit-based Incentive Payment System (MIPS) and those paid annual lump sums and excluded from MIPS quality-reporting requirements by sufficiently participating in qualifying advanced alternative payment models (APMs).
However, the list of qualifying APMs excluded ACOs in Track 1 of the Medicare Shared Savings Program (MSSP)—95 percent of the 434 MSSP ACOs are in Track 1.
Smaller ACO officials noted that it’s challenging enough to recruit physicians to ACOs without MACRA creating more disincentives. They expressed doubt that providers, if required to meet both ACO requirements and the new MIPS reporting, would continue ACO participation. A recent survey by the National Association of ACOs found that 56 percent of Medicare ACOs would likely leave the MSSP if they are ruled ineligible for the APM track under MACRA. (To download survey, click here.)
Impact on Physicians
HFMA wrote that “the vast majority of the 473 MACRA comments submitted by June 13 decried the impact of the law on small physician practices.” Many highlighted the implementing rule’s estimate that 87 percent of the nearly 103,000 solo practices would experience a combined pay cut of $300 million in 2019, the year the new payment system takes effect. (“Small ACOs Raise MACRA Concerns,” HFMA Weekly, June 17, 2016)
This could result in forcing physicians into larger practices or hospital employment, a prediction supported by hospital industry analysts. Solo practices probably would not be able to meet the increased quality reporting or electronic health record reporting requirements.
Hospitals employ almost 250,000 physicians and contract with almost another 290,000, according to one expert.
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