The CAP provided Congress with recommendations to improve Medicare’s payment program on October 31. In response to a congressional request for information regarding the potential reform of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the CAP provided feedback regarding pathologists’ experience in dealing with the current payment program and potential actions Congress could take to stabilize the Medicare payment system by reforming MACRA.

The MACRA legislation created a quality payment program for physicians that repealed the flawed sustainable growth rate (SGR) to end a cycle of annual Medicare payment cuts and reward value-based care. However, the MACRA program increased reporting burdens on physicians and has so far failed to stabilize the Medicare physician payment system, and physicians are now going to Congress each year to mitigate payment cuts The CAP continually advocates for fair pay for the value pathologists provide, while reducing reporting burdens.

In the October 31 request for information response, the CAP informed Congress of specific steps to stabilize the current Medicare payment system while furthering a successful transition toward value-based care. For instance, the CAP outlined the challenges of MACRA, including such as the lack of Physician Fee Schedule (PFS) updates to account for inflation and other practice costs, impact of budget neutrality requirements on these programs, and the significant administrative burden of the Merit-based Incentive Payment System (MIPS) program. The CAP provided specific recommendations to improve the MIPS and alternative payment model (APM) programs. Additionally, the CAP pointed out that “for MACRA to fulfill its purpose of increasing value in the health care system, Congress must consider reforms to the budget neutrality requirement within the current PFS system.”

In the letter, the CAP noted that participating in the MACRA payment programs is difficult as there are “limited options for physicians to participate…Single-specialty independent pathology practices are disenfranchised from being able to participate in the program as it evolves to APMs. And incentives for physicians to participate in both MIPS and Advanced APMs should recognize that high-value care is provided by both small practices and large systems, and in both rural and urban settings.”

As for recommendations that Congress can take to improve MACRA, lawmakers can ensure better financial incentives for quality and value and address the financial instability of the current Medicare physician payment system, the CAP said. The CAP did ask that Congress:

• Extend the exceptional performance bonus pool for the MIPS program, which rewards the highest performers with additional funds, supporting them in continuing to provide the highest quality care
• Continue the 5% Advanced APM Incentive Payment, ideally by passing the Value in Health Care Act (HR 4587)
• Pass the Supporting Medicare Providers Act of 2022 to ensure relief from scheduled budget neutrality cuts and, in addition, should waive the 4 percent PAYGO sequester triggered by the passage of the American Rescue Plan Act
• End the statutory freeze on annual Medicare physician payments and provide updates based on the Medicare Economic Index (MEI) in 2023 and beyond
• Mandate involvement of stakeholders in the development of new payment models
• Maintain traditional MIPS options for single specialty practices to ensure that private/independent practices of all sizes remain a viable option for physicians

The CAP will continue to work with Congress to address issues with the current MACRA payment program.