Industry Insights

Level Up:  Which MACRA or MIPS Path Is Right for You?

September 2016
Author:  Zach Remmich

Zach Remmich

Managing Consultant

Consulting

201 N. Illinois Street, Suite 700
P.O. Box 44998
Indianapolis, IN 46244-0998 (46204)

Indianapolis
317.383.4000

The Centers for Medicare & Medicaid Services (CMS) announced on September 8, 2016, that it intends to offer providers reporting flexibility within the Medicare Access and CHIP Reauthorization ACT (MACRA) for the first performance year, beginning January 1, 2017.

The proposed MACRA rule was released in April 2016. The provision would change how CMS pays clinicians providing care to Medicare beneficiaries by replacing the Medicare Sustainable Growth Rate formula and integrating several existing reporting programs. The proposed rule originally included two paths:  (1) Merit-Based Incentive Payment System (MIPS), and (2) Advanced Alternative Payment Models (APM). The recent CMS update offers two additional options for provider participation in the first year:

  1. Providers in 2017 can report “some” data through the Quality Payment Program. This “test the quality program” option would allow providers to avoid a negative payment adjustment in 2019. Acting Administrator for CMS Adam Slavitt says, “This first option is designed to ensure that your system is working and that you are prepared for broader participation in 2018 and 2019.”
  2. Providers may choose to submit data for a reduced number of days; they can participate for part of the calendar year, pushing back the January 1 start date, but will need to submit quality measures, improvement activity data and technology usage information to qualify for a small upward adjustment.

The update’s options 3 and 4 were already proposed in MACRA. Clinicians and practices may still choose the MIPS path within the proposed rule, which means providers would submit data to MIPS for a full calendar year and be subjected to an upward or downward adjustment on Medicare Part B payments. Option 4 is the original APM path within MACRA. Participation in an eligible APM qualifies providers for a 5 percent incentive payment in 2019, and they don’t need to submit data to MIPS.

While CMS hinted at a potential delayed reporting start earlier this summer, it appears this recent update is a middle ground, allowing providers to choose their pace of Year 1 participation. Few details have been released on the two new options, but CMS indicated more detail will be released when regulations are finalized. MACRA is currently a proposed rule. The final rule’s release is expected in early November 2016.

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