ASE Joins Letter on the MACRA Modernization Proposal

On May 14, ASE joined the Alliance of Specialty Medicine in submitting comprehensive comments on the Joint Congressional Doctors Caucus MACRA discussion draft. The Alliance supported the budget neutrality reforms in Title IV and access to Medicare claims data in Section 203, but raised a range of concerns across the rest of the draft. On the conversion factor update, the Alliance called for a permanent, full MEI update without reductions or caps. On MIPS reform, the Alliance opposed shifting more weight to quality and cost metrics before the underlying measurement problems for specialty physicians are resolved, objected to the removal of the Improvement Activities category, and asked for clarity on the proposed Cost Containment category and how it differs from the existing Resource Use category. The Alliance also raised concerns about the Quality Reform Task Force, noting that its recommendations are not binding on CMS and that the draft does nothing to address the resource and policy barriers that have already driven specialty societies away from MIPS measure development. On the MIPS adjustment reduction in Section 204, the Alliance cautioned that five years is not enough time to fix specialty measure gaps and warned against a sudden return to 9% adjustments in 2034. The Alliance asked that Section 205 on AUC be removed and addressed through the Quality Reform Task Force, and separately urged Congress to prohibit CMS from implementing the mandatory Ambulatory Specialty Model.

The Alliance’s concerns closely mirror ASE’s priorities. Its opposition to cost-heavy MIPS metrics, the Ambulatory Specialty Model, and a premature return to high payment adjustments all reflect challenges that echo practices face directly, particularly given imaging’s complex role in attribution and episode-based cost frameworks. The call for binding Task Force authority and specialty representation in quality measure development aligns with what ASE has consistently advocated for on behalf of echocardiography.