An article by MeetingsNet highlights the CME Coalition's role in spearheading hundreds of comments submitted to the Centers for Medicare and Medicaid (CMS) describing the value of CME to the Merit-Based Incentive Payment System track of the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA. Among the CME Coalition’s comments, the article details, was a suggestion that CMS “explicitly recognize qualifying CME as a clinical practice improvement activity within MIPS because CME has long been recognized as an effective means by which physicians demonstrate engagement in continued professional development.”
CME Community Speaks Out on Proposed Merit-Based Income Payment System
Accreditation Council for Continuing Medical Education President and CEO Graham McMahon, MD, was among the more than 300 individuals and organizations in the CME community who submitted comments to the Centers for Medicare and Medicaid Services (CMS) describing the value of CME to the Merit-Based Incentive Payment System track of the Medicare Access and CHIP Reauthorization Act of 2015, or MACRA. CMS’s proposed regulation to implement MACRA was released April 27, 2016.
MACRA replaces the “patchwork system of Medicare reporting programs with a flexible system that allows you to choose from two paths that link quality to payments: the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs),” according to the CMS website.
This signals a shift away from fee-for-service reimbursement and toward pay that’s based on quality and cost of care. MIPS absorbs components of the Physician Quality Reporting System, the Value-Based Payment Modifier, and the Medicare Electronic Health Record Incentive Program. It also will be the track used by most physicians and other healthcare professionals due to the high bar set to qualify under APMs, which mainly apply to accountable care organizations, patient-centered homes, and bundled payment models, according to CMS. HCPs will begin to be graded under the new system starting in 2017, affecting HCP payments starting in 2019.
The CME Angle
Why does this matter for CME? MIPS uses a 100-point score, 15 percent of which comprises practice improvement activities. Many in the CME community—including theACCME—believe that CME can play an important role in this area.
“The ACCME’s educational system and technological framework can be readily leveraged to support the implementation of MIPS, and help our clinician community maintain and advance the quality, safety, and efficiency of care for the patients we all serve,” wrote McMahon in his comments to CMS.
Among the ACCME’s suggestions were that CMS “recognize relevant performance and quality improvement accredited CME as a clinical practice improvement activity within MIPS; and that CME designate ACCME’s Program and Activity Reporting System (PARS) as a reporting mechanism for clinical practice improvement activities.”
The CME Coalition, which advocates for the CME community in Washington, D.C., held a well-attended webinar in June to encourage more providers to submit comments before the June 27 deadline. It also submitted comments on MACRA. According to a CME Coalition estimation, more than 300 have submitted CME-related comments to CMS, though just more than half of them have been processed and are available in the database as of press time.
Among the CME Coalition’s comments was a suggestion that CMS “explicitly recognize qualifying CME as a clinical practice improvement activity within MIPS because CME has long been recognized as an effective means by which physicians demonstrate engagement in continued professional development.” The Coalition also pointed out that ACCME’s PARS could easily be integrated into the MIPS reporting platform, and recommended that CMS acknowledge and provide credit for CME activities as clinical practice improvement activities within MIPS as long as they:
• are provided by a CME provider that is accredited by a nationally recognized accreditor,
• involve assessment and demonstrated improvement of patient outcomes or care quality, and
• teach the principles of quality improvement and the basic tenets of MACRA implementation.
The network of CME professionals included in the ACCME system "understands healthcare needs on the local community, regional, and national levels; has expertise addressing public/population health challenges; and has demonstrated success in overcoming implementation challenges,” wrote ACCME’s McMahon. “This network has the capacity and expertise to engage clinicians in meaningful work to improve performance, practice, and quality improvement.”
The MACRA final rule is due to be released by year’s end.