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Elizabeth Arend

Quality Improvement Advisor

Take Action: Submit Your Comments on MACRA Regulations

June 23, 2016 | Medicare | Quality | Take Action | Comments
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Thank you to all who provided input on the National Council’s comments on the Medicare Access and CHIP Reauthorization Act (MACRA) Proposed Rule. Considered one of the most significant pieces of Medicare legislation in decades, MACRA eliminates the Sustainable Growth Rate formula, and establishes a new Quality Payment Program that will fundamentally change the way in which Medicare reimburses clinicians. Public comments on the proposed rule are being accepted through Monday June 27, 2016.

The National Council comments urge the Centers for Medicare and Medicaid Services (CMS) to consider in its implementation and policies the unique situation of specialty behavioral health organizations, which have not benefited from either federal and state investments in health information technology incentives nor national agreement on standardized quality and utilization measures.

The National Council supports several components of the proposed rule, most especially that it streamlines multiple quality reporting programs into one, and that it incentivizes certain clinical practice improvement activities such as the integration of behavioral and physical health. However, the National Council notes several concerns, including the limited number of behavioral health quality measures, and the way in which behavioral health providers’ performance will be evaluated and scored relative to providers in other fields.


Today, we are issuing a template comment form that can be use as the basis for members’ comments to CMS. To submit your comments:

  1. Download the template comment letter.
  2. Personalize it where indicated with information about how your organization.
  3. Submit your comment online at (click “Comment Now” in the right-hand sidebar and fill in all required information.)



In the meantime, keep an eye out for the National Council’s upcoming webinar series on MACRA’s Quality Payment Program in August! This three-part series will help Medicare Part B providers:

  • Understand how quality will be tied to Medicare payments under MACRA’s Merit-Based Incentive Payment System (MIPS)
  • Identify quality measures that pertain to behavioral health
  • Strategize to avoid future negative payment adjustments

Note: Registration information to follow in separate email communications from the National Council.


Feel free to contact Elizabeth Arend with your MACRA-related questions at