NCHC Backs Elements of MACRA Rule, But Expresses Concern About Flaws in APM Proposals

NCHC Writer
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Contact: Nisha Bhat
                National Coalition on Health Care
                [email protected]
                202-638-7151, ext. 106

NCHC Backs Elements of MACRA Rule, But Expresses Concern About Flaws in APM Proposals

WASHINGTON, DC— In comments submitted today to the Center for Medicare and Medicaid Services, the National Coalition on Health Care (NCHC), an alliance of leading national health care, consumer, labor and business groups, combined support for elements of CMS’ approach to MACRA implementation with concern that a few flawed provisions could undermine the law’s objective of promoting alternative payment models (APMs).

There is a great deal to like in the proposed rule. But CMS must fix some crucial problems or risk discouraging participation in the APMs that MACRA was designed to promote,” said NCHC President and CEO John Rother.

In the letter, NCHC praises CMS for proposals that emphasize outcome-based quality metrics, as well as its efforts to establish a glide path toward broader participation in APMs and Advanced APMs.  However, NCHC does identify substantive problems with the rule’s provisions related to alternative payment models, including:

  • the exclusion of episodic bundling models other than the Oncology Care Model from both the MIPS APM and the Advanced APM categories;
  • provisions which could slow providers’ embrace of Advanced APMs within Medicare Advantage; and
  • a flawed framework for determination of Qualifying and Partially Qualifying Advanced APM Participants which discourages participation in Advanced APM models.

NCHC was a strong supporter of MACRA’s enactment, arguing that the legislation was vital to health care affordability.

“More affordable health care demands that we must successfully move beyond volume-centric, fee-for-service medicine,” said Rother. “That’s why it’s so important to get this law’s implementation right.”

Read the full NCHC comment letter here.


The National Coalition on Health Care (NCHC), the oldest and most diverse group working to achieve comprehensive health system reform, is a 501(c)(3) organization representing more than 80 participating organizations, including medical societies, businesses, unions, health care providers, faith-based associations, pension and health funds, insurers and groups representing consumers, patients, women, minorities and persons with disabilities. Member organizations collectively represent – as employees, members, or congregants – over 100 million Americans.

Some members of NCHC do not, or cannot, take positions either on specific legislation, strategies or on any policies outside their respective mission areas. However, all that can, do endorse broad policy positions in support of comprehensive health system change.