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Advocacy
Organizations that have an impact on CME will periodically request public feedback to changes they are considering, in the form of Calls for Comment. TACME represents its members in these Calls for Comments. Participation and input is welcomed and encouraged. If you are interested in participating in future discussions related to advocacy issues such as these, please email TACME. Your comments are always welcome and encouraged!
June 2016
TACME Comments on MACRA
On April 27, 2016, CMS released its proposed regulation to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposed rule creates a "Quality Payment Program" to replace old reporting programs. There two tracks, the first called the Merit-based Incentive Payment System (MIPS) and a second track involves alternative payment models (APM). MIPS is based on a 100-point score, with clinical practice improvement activities (CPIA) representing 15 percent of the score. This is an area where CME can play an important role in helping CMS achieve its quality measure objectives. The proposed rule leaves great discretion to the Secretary of HHS to define what will be included in these activities. As stated in the rule's preamble: "Clinical Practice Improvement Activity (CPIA) means an activity that relevant eligible clinician organizations and other relevant stakeholders identify as improving clinical practice or care delivery and that the Secretary determines, when effectively executed, is likely to result in improved outcomes."
According to the statute, any CPIA measure must be "relevant to an existing CPIA subcategory (or a proposed new subcategory)" as defined in the law. Unfortunately, those subcategories do not currently include a specific reference to medical education. However, the language defining CPIA, when coupled with the authority granted to the Secretary of HHS as proposed, offers a real opportunity for advocates of CME to argue that CME should be included in the measurement category. In short, CME should be a means by which doctors get credit under MIPS because it improves beneficiary outcomes, leads to practice improvement, can be performed by providers of all types, is feasible to implement, can be validated by CMS, and is evidence-based!
A Call for Comments was requested and below is TACME’s submission on behalf of TACME members and those in our profession from the state of Texas. For more information please visit http://www.cmecoalition.org/macra.html.
TACME Comments on MACRA
On April 27, 2016, CMS released its proposed regulation to implement the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The proposed rule creates a "Quality Payment Program" to replace old reporting programs. There two tracks, the first called the Merit-based Incentive Payment System (MIPS) and a second track involves alternative payment models (APM). MIPS is based on a 100-point score, with clinical practice improvement activities (CPIA) representing 15 percent of the score. This is an area where CME can play an important role in helping CMS achieve its quality measure objectives. The proposed rule leaves great discretion to the Secretary of HHS to define what will be included in these activities. As stated in the rule's preamble: "Clinical Practice Improvement Activity (CPIA) means an activity that relevant eligible clinician organizations and other relevant stakeholders identify as improving clinical practice or care delivery and that the Secretary determines, when effectively executed, is likely to result in improved outcomes."
According to the statute, any CPIA measure must be "relevant to an existing CPIA subcategory (or a proposed new subcategory)" as defined in the law. Unfortunately, those subcategories do not currently include a specific reference to medical education. However, the language defining CPIA, when coupled with the authority granted to the Secretary of HHS as proposed, offers a real opportunity for advocates of CME to argue that CME should be included in the measurement category. In short, CME should be a means by which doctors get credit under MIPS because it improves beneficiary outcomes, leads to practice improvement, can be performed by providers of all types, is feasible to implement, can be validated by CMS, and is evidence-based!
A Call for Comments was requested and below is TACME’s submission on behalf of TACME members and those in our profession from the state of Texas. For more information please visit http://www.cmecoalition.org/macra.html.
| TACME Response the CMS MACRA |
February 2012
CMS – PROPOSED RULE RELATED TO THE PHYSICIAN PAYMENTS SUNSHINE ACT (PPSA) – This proposed rule would require applicable manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid or the Children’s Health Insurance Program (CHIP) to report annually to the Secretary certain payments or transfers of value provided to physicians or teaching hospitals (“covered recipients”). In addition, applicable manufacturers and applicable group purchasing organizations (GPOs) are required to report annually certain physician ownership or investment interests. The Secretary is required to publish applicable manufacturers’ and applicable GPOs’ submitted payment and ownership information on a public Web site.
Original Call for Comment
CMS – PROPOSED RULE RELATED TO THE PHYSICIAN PAYMENTS SUNSHINE ACT (PPSA) – This proposed rule would require applicable manufacturers of drugs, devices, biologicals, or medical supplies covered by Medicare, Medicaid or the Children’s Health Insurance Program (CHIP) to report annually to the Secretary certain payments or transfers of value provided to physicians or teaching hospitals (“covered recipients”). In addition, applicable manufacturers and applicable group purchasing organizations (GPOs) are required to report annually certain physician ownership or investment interests. The Secretary is required to publish applicable manufacturers’ and applicable GPOs’ submitted payment and ownership information on a public Web site.
Original Call for Comment
| TACME Response to PPSA |
June 2011
ACCME – Disclosure of Commercial Support – The ACCME has issued a call for comment about a proposal that would prohibit the use of corporate logos and the mention of corporate divisions in disclosures of commercial support. The call for comment relates to Standard 6 in the ACCME Standards for Commercial SupportSM , which says that providers must disclose to learners the sources of commercial support.
ACCME – Disclosure of Commercial Support – The ACCME has issued a call for comment about a proposal that would prohibit the use of corporate logos and the mention of corporate divisions in disclosures of commercial support. The call for comment relates to Standard 6 in the ACCME Standards for Commercial SupportSM , which says that providers must disclose to learners the sources of commercial support.
| TACME Response to Disclosure of CS |
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