There are terms that conjure dread in certain groups: LDL for middle-aged people, Brexit for London bankers, Presidential elections 2016 for Americans and MACRA for clinicians.
Most clinicians don’t know much about it. Those that do, find little to appreciate. Everyone agrees that the intention behind the law is noble but it is steeped in implementation challenges.
CMS set out to allay these fears in the Final Rule which came out on October 14, 2016. By and large, we believe CMS has hit a home run as the updated MACRA timeline and implementation reflect great flexibility. CMS is meeting providers where they are at, allowing some of the less advanced providers to transition in while also allowing the advanced ones to do more under the law and thus, earn more of a payment adjustment.
What has changed? There are four pathways to choose from while transitioning to new reimbursement models, eligibility criteria have been changed with more people exempt from participating in 2017, performance measures under MIPS have been reduced ,CMS has promised to add more models to the qualifying APM track and the nominal risk requirement for advanced APM has been lowered.
What has not changed? MIPS payments start in 2019, based on the quality of care starting with 2017. Hence, 2016 (whatever remains of it) is an important year for you to understand and strengthen quality benchmarks.
Download : MACRA for Dummies- Summary of the Final Rule
As a physician, you have to start now, to ensure you’ve implemented the tools and resources needed to baseline your performance and jumpstart the MACRA journey.
So what should you do?
- Determine if you qualify for a low-volume exemption. CMS will exempt physician practices with less than $30,000 in Medicare charges or fewer than 100 unique Medicare patients per year. You will also be exempt if you are in your first year as a Medicare provider.
- Review CMS four proposed participation options for 2017. By selecting an option you will avoid negative payment adjustment in 2019.
- Contact your EHR vendor to inquire about its plan for implementing MACRA. Determine what capabilities your system will offer for reporting some, or all, MIPS data. Be sure to document these conversations.
- Physicians may participate in MIPS as an individual or group. Consider which option might work better for your practice. Do remember that a practice that elects to have its performance assessed as a group will be assessed as a group across all four MIPS performance categories, and physicians within a practice must aggregate their performance data across the group in order for their performance to be assessed as a group.
- While all physicians must participate in MIPS in the first performance year, you should consider whether you may currently participate in an advanced APM that meets the criteria, or want to work toward participating in future years. Be sure to consider that requirement for APM participation increase steadily in the coming years.
- If you did not report for PQRS or meaningful use, then evaluate the penalties and your readiness for MACRA.
Quality is by far the most important MIPS component for the 2017 and 2018 performance years, accounting for at least 60% of physicians’ final score for 2017 performance (and 50% in the 2018 performance year).
- Review your current and recent PQRS reporting system and feedback reports. Feedback reports are available through the CMS Enterprise Portal. Determine what measures you currently report and in which you are most successful. MIPS includes a key change to reward physicians for the achievement of quality benchmarks for the measures, not just requiring the measures be reported. Since MIPS scores reflect performance rather than just reporting, there is an obvious incentive to choose measures on which you (or your practice) are likely to score well.
- For reporting systems, things have not changed. You can either report through claims, qualified registry, EHR submission mechanism or CMS website interface. However, the reporting system you choose will come with its own set of pros and cons. Be sure to look through them with an expert.
- Though you may continue using the same reporting system into 2017, CMS has indicated its preference. It makes it clear that it does not favor claims submission for quality performance measurement, and physicians and groups choosing this method to submit quality data in 2017 may be well advised to make plans to transition to the registry, QCDR or CEHRT submission in future years.
Clinical Practice Improvement Activities
- This is a new category and does not correlate to any existing quality reporting program. Review the current list of proposed activities and determine which might work for your practice.
Advancing Care information
- Please note that this component of MIPS is not counted for hospital-based physicians. If at least 75% of services are provided in inpatient, emergency room, and on-campus hospital outpatient settings, you may qualify as hospital-based for MIPS purposes.
- When the score for this category is zero, either because the physician is hospital based or because s/he qualifies for an exception, the weight that would otherwise be accorded to this component is shifted to the quality component.
- It is ok to use 2014 or 2015 Edition Certified EHR for 2017. However, for the 2018 performance year and subsequent years, the CEHRT must meet the 2015 Edition Base EHR definition.
- Required measures include security risk analysis, e-prescribing, providing patient access, sending a summary of care and requesting and accepting the summary of care. The required measures must be fulfilled for a minimum of 90 days to receive credit.
CMS will not weigh the cost component of MIPS for 2017 and it will only count for only 10% of a physician’s score for the performance year 2018; however, this component of MIPS ultimately will count for 30% of a physician’s overall score. Therefore, it is worth paying attention to your score on this component of MIPS in 2017 even though it won’t “count.”
While the final rule has thrown light on how MIPS will pan out, APMs still remain a mystery to many. The currently available models are, for the most part focused on primary care. Things are expected to become clearer in 2017 with more models qualifying as advanced APMs. Till then most clinicians should prepare to participate in MIPS.
All in all, healthcare reimbursement is changing and there is limited time to prepare for it. Though we have tried to highlight parts of the final rule, there is still a lot more to learn. Watch our latest webinar to stay on track with MACRA.