The American Association of Neurological Surgeons and Congress of Neurological Surgeons provided feedback on CMS's request for input on the Medicare Access and CHIP Reauthorization Act.
The organizations believe these principles are integral to a successful MACRA implementation:
1. Gradual, thoughtful implementation. Programs like the Physician Quality Reporting System and Electronic Health Record Incentive Program were flawed in implementation, making them unnecessarily burdensome. AANS/CNS recommended proceeding cautiously to avoid further disruption.
2. Flexibility for meaningful engagement. The organizations prefer a flexible instead of prescriptive approach. This will ease the transition and foster trust, innovation and utilization.
3. Investment in measure gaps. The ongoing lack of relevant quality and cost measures has had a significant barrier to meaningful participation in some specialties. AANS/CNS hopes CMS will work with specialties to close the measures gap and develop more specific episode-based cost measures.
4. Re-define meaningful use. The current meaningful use incentive strategy is unsustainable. Instead, future strategies shouldn't be all-or-nothing or pass-fail, and physicians have varying control over EHR choice.
5. Promote clinical data registry value. The organizations support CMS' investment and promotion of qualified clinical data registries and hope CMS will keep investing in more robust data.
6. CMS must monitor the new programs. CMS should monitor the regulatory burden of new policies on practicing physicians so compliance isn't a meaningless engagement, and won't interfere with direct patient care.