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NAACOS and Others Urge CMS to Immediately Recognize MA Advanced APM Participation under MACRA 

WASHINGTON, D.C. (June 1, 2017) 

Letter urges CMS to revise regulations to allow qualifying MA contracts to be used to meet the minimum requirements for MACRA’s 5 percent Advanced APM bonus

In a joint letter sent to the Centers for Medicare & Medicaid Services (CMS) yesterday, NAACOS and nine other organizations urged the agency to modify regulations to give credit under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) for participation in Medicare Advantage (MA) Advanced Alternative Payment Models (APMs). The letter requests that MA contracts meeting CMS requirements for quality, risk and use of certified electronic health record technology be immediately counted in calculations to qualify ACOs and other Advanced APM entities for 5 percent MACRA bonuses. The joint comments represent the collective views of organizations representing physicians, medical group practices, hospitals, health plans, employers, nearly all ACOs, and other stakeholders leading the way to value-based care. 

The MACRA Quality Payment Program (QPP) requires that ACOs and other organizations in Advanced APMs meet certain thresholds to demonstrate their commitment to the Advanced APM. These Qualifying APM Participant (QP) requirements are based on meeting a minimum threshold of either revenue or number of patients that go through the APM. While the QP thresholds focus initially on fee for service (FFS) Medicare, in later years the agency gives credit for Advanced APM participation with payers outside FFS Medicare, including MA, Medicaid and other commercial contracts. 

The letter specifically urged CMS to modify its patient count method for calculating the QP thresholds starting with the first performance year in order to provide credit for MA Advanced APM participation as soon as possible. “It’s essential to recognize the work ACOs are doing with MA plans to propel the shift to value-based care and alternative payment models,” said NAACOS President and CEO Clif Gaus. This is especially important considering the continued growth of MA in the overall Medicare program. Gaus notes, “It makes little sense to wait to count MA Advanced APM participation when those efforts reinforce the goals of MACRA.” The letter also urged CMS to harmonize the financial risk requirements across payers participating in APMs.