On December 18, 2015, CMS released its draft plan for developing the quality measures that will be used within both the MIPS and APM components of MACRA. The purpose of this draft plan and the mandate for the Secretary of HHS, at least theoretically, is to:
- Address how measures used by private payors and integrated delivery systems could be incorporated into Title XVIII (i.e., Medicare).
- Describe how coordination across organizations developing such measures might occur.
- Take into account how clinical best practices and clinical practice guidelines should be used in the development of quality measures.
What’s clear is that behind CMS’s high hopes for MACRA are a lot of loose ends. Stakeholders who have been closely monitoring the unfolding of MACRA’s details might have anticipated valuable insights to help them prepare for the implementation of these measures in 2019, just 3 years away. Unfortunately, the draft plan offers little (if anything) that is new and useful.
Instead, despite its length of 61 pages, the document deals only in generalities. For example, it includes a timeline containing key milestones between now and the implementation date – most of which were already established in the legislation – without revealing specifics around the activities associated with those milestones. There is a rather extensive discussion of CMS’s strategic vision for measure development priorities that merely hints at how measures will be selected (e.g., General Principle #10 is to “focus on what is best for patients and caregivers for each decision made during the development life cycle”).
The approach to achieving that vision is communicated through similarly vague and aspirational language such as “CMS will leverage multi-stakeholder groups to identify the issues related to the development of measures that can be applied across payers and delivery systems.” No word on how this leverage will actually occur, through what process, or when results are to be expected.
CMS must release its final plan on May 1, 2016, and will be receiving public commentary on the draft plan until March 1. Provider organizations should familiarize themselves with the plan and make their voices heard through professional associations, letters to Congress, and other appropriate means. In the meantime, ECG will continue to monitor the rollout of MACRA and will provide updates through blog posts and other channels.