Congress of the United States ‘Washington, DE 20515 August_,2016 Me, Andrew Stavtt Acting Administeator Centers for Medicare and Modiaid Services 200 Independence Avenue SW, Room 314-6, ‘Washington, D.C. 20201-0001, Dear Acting Administrator Slvi: ‘We are writing foday to address concerns and recommend changes regarding your proposed rule onthe implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), or “Doc Fix” Replacement. Since is passage, Members of Congyess have come to understand the fll scope of 'MACRA implementation and received additonal information on the challenges these new requirments pose for piysicins and patients, [tis our desire to ensure congressional intent is respected and achioved thoughour your final rulemaking process, {thas come to our attention that physicians nationwide who once applauded and thanked us fr repealing SSGR are now beginning to fear what they beliove i simply a tade in hari policy and destructive regulation. MACRA and the MeritBased Incentive Payment System (MIPS) are far more complex, ‘confusing, and controlling than the Physician Quality Reporting System, meaningful use, and value-based ‘modifier prograns they are replacing. The compliance and reporting Fequitements related to the new Incentive programs are exceedingly expensive for physicians and their practices, Your own figures Suggest that that these new programs Will add an additional compliance cost of $128 milion above the pre-existing cos ofthe programs they are replacing. Even if practices have the time, financial means, and ‘ministrative bandwidth to dedicate to regulatory compliance, they may fae payinent penalties due to documentation and/or system error, and the unpredictable nature of the measurement systems. More ‘importantly, these proposed MACRA regulations will acselerate the deterioration inthe patent-physican telaionship and the experince of care only fr the sake of bureaucratic excass, We need more patient, Tess paper. (ne trubing featre of MIPS is that it clearly disadvantages smaller, independent practices. The need far sophisticated support systems, the flexibility ofthe measurement standards, andthe lace of realistic incentives to change all rete pressures for physicians to abandon small practices to join large ones — or to sell otto hospital. In fact, your own estimates again demonstrate 87 pereent of eligible clinicians in solo practice will experience acut in Medicare payment rates. In Texas, more than 60 percent of patient are pliysicians are in small practices of one to thee physicians. MACRA is very likely to place an enormous burden there and on largely ural areas, making access to care challenging forthe many ‘Medicare beneficiaries in snaller communities Inthe pursuit of quality measures, we must ensure -MACRA regulation promotes a pathway for succes for independent practices. “Those who are impacted the most ~ our clinicians ~ wll find themselves spending entirely too much time {sing their actions instead of allowing ther actions to speak for themselves. Quality of care must be ‘efined by patient-centered outcomes, ahr than paperwork. Because we do not fel that our concerns fan be addressed in a timely fashion given the stat date of January 1, 2017, we respectfully urge the following changes be made othe proposed rulePublily announce a delay of MACRAIMIPS implementation unt at least January 1, 2018, + Engnge with stakeholders, including the nation's largest national physic stat associations. Specifically, we strongly encourage you To engage the nation’s largest state ‘medical society, the Texas Medical Assocation who has already authored extensive recommendations afer wide-ranging study and discussion among its membership. 2s councils and + Initiate open forums to discuss and ceive feedback for better remaking, ineling «coordination on Capitol Hill with interested Members of Congress. ‘+ Based upon findings fom these meetings and forums, publish Final rules a least sic mnths prior tothe implementation date, ast allow adequate time for physicians and providers to prepare forthe upcoming changes to their practices. ‘Thank you for your attention to this vitally impostant matter. We look forward to working closely (0 ‘ensure congressional inlent i carried ou in a matter that respects the patiea- physician relationship aud Promotes timely access to quality cost-effective heath eate while ensuring, no one in the medical ‘community is unduly harmed, Pete Sessions “Member of Congress Memberof Congress Member of Congress Monier of Congress Member of Congsess Member of Cones ‘Member of Congress ‘Member of Congress ‘Meniber of Congress Meniber of Congress ‘Member oF Congress ‘Member of Congress ‘Member oFCongsess “Member of Congress