On October 14, 2016, the Centers for Medicare & Medicaid Services (CMS) released the much anticipated final rule implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA repeals the sustainable growth rate formula and solidifies two new payment systems: the Merit-Based Incentive Payment System (MIPS) and Advanced Payment Model (APM) track.
The release provides more detail surrounding MIPS and APM in year one, a reduced reporting timeline, the re-weighting of MIPS categories (no cost in year one) and higher eligibility thresholds for clinicians, among others.
It’s evident CMS has acknowledged anxieties expressed by physicians and providers in regard to this new program’s potential effect on their ability to efficiently manage their practices. What remains to be seen is how physicians and providers will respond to the new changes and how the incentives in this rule will affect their behavior.
CMS finalized the first performance year, 2017, as a transition year—clinicians will have greater flexibility in how they submit data. MIPS-eligible clinicians have multiple reporting options under MACRA. Do you know which path is right for your organization?
While MACRA may affect each MIPS-eligible clinician and group differently, there are several key considerations all participants should review to assess their MACRA readiness. These are immediate considerations for clinicians in preparing for the new quality payment program:
- Assess clinician eligibility – Clinicians should assess the eligibility of MIPS with the final rule requirements by reviewing historical Medicare Part B payments and volumes.
- Assess current quality reporting performance – Clinicians should understand quality reporting requirements and identify potential reporting metrics based on historical performance or area of expertise. A good starting point is accessing and reviewing Medicare Quality and Resource Use Reports to identify improvement areas.
- Determine reporting strategy – Analysis to determine optimal reporting based on specialty, quality outcome performance and MIPS status, e.g., nonpatient facing and facility-based, to name a few, may identify various reporting strategies to improve performance with MIPS that would otherwise go undetected.
- Identify future reporting strategy – Clinicians should evaluate their infrastructure in regard to reporting under MIPS and identify what MACRA track is feasible for the organization while aligning with organizations that will help improve quality and decrease costs.
- Stay informed – CMS has indicated it expects to reopen the Comprehensive Primary Care Plus (CPC+) application process and may retrofit bundled payment models to meet advanced APM criteria under MACRA.
Additional resources for MACRA can be found at the CMS Quality Payment Program website. Join us for “MACRA Applications & Implications Part 2: The Final Rule” to understand and identify implications and reporting and participation strategies.