MACRA is paved with good intentions but steep in implementation challenges. It is a monumental task for anyone reading the final rule issued by CMS on October 14, 2016, for the implementation of the Medicare Access and CHIP Reauthorization Act (2017).
The document is indeed full of legal intricacies. The good news is: MACRA will pay physicians for continuing to do what they always wanted to do: provide the best possible care in the best interest of their patients.
Now for the bad news: MACRA marks the most significant change to clinician reimbursement in more than 20 years; and we all have to be ready.
The updated MACRA timeline is still aggressive, but its final adjustments reflect greater flexibility than what was outlined as recently as June, 2016.
Performance measures will still go into effect in 2017, so let’s get up to speed on how this intricate program will affect your organization.
As a physician, you have to start now to ensure you’ve implemented the tools and resources necessary to baseline your performance and jumpstart the MACRA journey.
MIPS payments start in 2019 based on the quality of care starting with 2017. Hence, 2016 an important year for you to understand and strengthen quality benchmarks.
So what should clinicians do? What can they expect as far as technology is concerned?
By 2017, the clinicians should:
- Use a 2014 or 2015 Edition Certified EHR
- Decide which track they will choose for reporting to CMS
- Report on stage 2 or 3 care information objectives and measures
- Allow ONC to review their EHR and provide support for HIE
- Continue to ensure consistent, timely, and personalized care for each of their patients
A key concern is how aggressively the MIPS program will redistribute payments from low performers to high performers. Combing through the momentous document, we found that CMS noticed the concerns of small practices and Congress about the framework’s impact on small practices, and expanded its exclusion for providers who treat a small volume of Medicare patients from MIPS. CMS will now provide $100 million in technical assistance to clinicians participating in MIPS who are in small practices, rural areas, and areas with shortages of health professionals. To help ease the impact on small providers, CMS will exempt physician practices with less than $30,000 in Medicare charges or fewer than 100 unique Medicare patients per year. The draft rule has set the threshold at $10,000 a year.
The final regulations also address requests for lower minimum reporting thresholds. CMS originally wanted providers to report quality measures on 90% of their patients from all payers, and 80% of Medicare patients. Small providers argued they would have a harder time obtaining the information technology and data needed to meet that requirement. The final rule drops the Medicare threshold to 50%.
CMS will also be expanding opportunities to participate in programs that qualify as “advanced alternative payment models” under the law. Practices with a significant portion of their revenue under such a model are exempt from MIPS and qualify for larger rate increases and bonuses.
MACRA will enable provider affiliations to be characterized by tight partnerships through which the entities can share capabilities. Smaller, independent practices may actually have more agility as the sole authorities in crafting their respective MACRA strategies. Independent medical groups will have more flexibility in what they do to respond to MACRA, flexibility that medical groups associated with hospitals or health systems won’t have.
As providers address MACRA, they need to address not only MIPS/APMs, but also Medicare Advantage, Medicaid incentives, and commercial insurances. All in all, not only is regulatory reporting going to be substantial, the financial incentives will be significant. Hence, the clinical and financial outcomes of your practice are tightly co-related as MACRA goes into effect.
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