American Chiropractic Association Comments on MACRA 2018 Proposed Rule

Arlington, Va. – The American Chiropractic Association (ACA) recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) in response to the federal agency’s proposed rule changes to the Quality Payment Program (QPP) for 2018.

QPP is a new payment model for physicians, including chiropractors, created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

“ACA strongly supports the agency’s efforts to further develop the methodology that ties annual Physician Fee Schedule (PFS) payment adjustments to value-driven, quality care,” said ACA President David Herd, DC. “The QPP will encourage participation in Alternative Payment Models (APMs) by creating an incentive program. The provision to supply technical assistance to small practices and practices in health professional shortage areas will also be helpful for chiropractic participation. ACA hopes the low-volume threshold will remain the same.”

ACA’s comments included the following points:

  • Low-Volume Threshold (LVT) – While ACA supports a low-volume threshold to exclude small practices, we oppose increasing the current LVT to the proposed levels because it would virtually eliminate chiropractors from Merit-based Incentive Payment System (MIPS) participation. Additionally, ACA encouraged CMS to allow clinicians who would be excluded by the LVT the ability to opt-in if they so choose.
  • Virtual Groups – ACA commended CMS for further developing the concept of virtual groups (i.e., groups established among small practices, possibly separated geographically to further encourage participation in MIPS), however, most small practices that would participate in MIPS via virtual groups would be excluded due to the LVT. ACA encouraged CMS to allow small practices to opt-in to MIPS via virtual groups regardless of their exclusionary status due to the LVT.
  • Submission Mechanisms – ACA is encouraged by CMS’ proposal to allow clinicians to submit through multiple submission mechanisms. This provides clinicians with the flexibility they need to submit meaningful measures.
  • Measures and Scoring – ACA voiced several concerns over the proposals for Quality, Cost, Improvement Activities and Advancing Care Information categories. Most notably, DCs are at a disadvantage when reporting measures because they are limited to only reporting three CPT codes. ACA encouraged CMS to expand the billable codes allowed for chiropractors so that could participate in MIPS in a more meaningful way. ACA also commended CMS for proposing to establish a clear exclusion for e-Prescribing, as well as continuing to offer hardship exclusions for Advancing Care Information measures.

To see the full proposed rule changes, visit CMS’ website at The final rule will be published in the fall, most likely in November. ACA will continue covering updates on Medicare and QPP in its member communications. For more information on MACRA, visit

About the American Chiropractic Association
The American Chiropractic Association (ACA) is the largest professional association in the United States representing doctors of chiropractic. ACA promotes the highest standards of ethics and patient care, contributing to the health and well-being of millions of chiropractic patients. Visit us at