The American Medical Association (AMA) has published an “Action Kit” summarizing the proposed rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA) and highlighting its preliminary comments and recommendations for changes to the proposed rule.

Among the issues that the AMA highlights for changes are mitigating the adverse impact of the proposed rule on solo and small group physician practices, reducing the two year look-back for the performance period, tailoring the quality measures for specialists and physicians in ambulatory rather than hospital-based practices, greater incentives for using electronic reporting of quality measures, more sophisticated and appropriate resource use measures, greater flexibility on health information exchange and patient engagement measures, the full year reporting for advancing care information, refining the definition of nominal risk for Advanced Alternate Payment Models (APMs), and more definition of APMs that are not “advanced” but would provide credits under the Merit Incentive Payment System (MIPS).

Many stakeholders are continuing the analyze the nearly 1,000 page proposed rule, and conducting information sessions to educate and mobilize their constituencies to comment on the proposed rule. Comments on the proposed rule are due on June 27, 2016.

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