After the proposed Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule was issued in April 2016, many clinicians, provider groups and associations expressed concerns to the Centers for Medicare & Medicaid Services (CMS) on the time available to review, select and implement reportable measures. When CMS issued the final MACRA rule on October 14, 2016, it was apparent the agency heeded those concerns.
The final rule also allowed clinicians to pick their pace with four options for Merit-Based Incentive Payment System (MIPS) track participation for performance year 2017:
- Clinicians who don’t wish to report any 2017 data to Medicare will receive a negative 4 percent payment adjustment in 2019.
- Clinicians who choose to test the data collection and submission process by reporting a minimum amount of data in 2017 can avoid negative payment adjustments in 2019. These practices will be required to report one measure in the quality performance category, one activity in the improvement activities category or the required measures of the advancing care information performance category.
- Clinicians who choose to report to MIPS for less than the full-year performance period in 2017 but for a minimum, full 90-day period may earn a neutral or small positive payment adjustment in 2019. These practices will be required to report more than one quality measure or improvement activity or more than the required measures in the advancing care information performance category.
- Clinicians who choose to report to MIPS for a full 90-day period—or ideally the full year—may earn a moderate positive payment adjustment in 2019. These practices will be required to meet all requirements for quality, advancing care information and clinical practice improvement activities.
Despite the added flexibility and evaluation time from practices being given participation-level choices in the 2017 performance year, complacency is a potential danger. It will be a full performance year in 2018, meaning all practices that aren’t exempt from MIPS reporting will be required to submit data for the full year. In addition, the maximum upside opportunity or downside risk to 2020 reimbursement increases to 5 percent, compared to 4 percent in 2019. Practices or individual providers who aren’t actively preparing for that full performance year run a significant risk of failing to put the appropriate systems, procedures, education and reporting capabilities in place before 2018.
Practices should begin forming MACRA steering committees responsible for readiness assessment, measure selection, process improvement, ongoing monitoring and other functions. Because of steering committee formation, work plan development and operationalizing, planning can be time-consuming and practices should begin as soon as possible. Starting now will allow those practices to identify and improve any areas of their processes or systems that don’t meet stated goals or need to increase efficiency.
The first MACRA performance year quickly arrived—so will the 2018 performance year. Regardless of the reporting option chosen for 2017, the goal for any practice should be a smooth transition into a full performance year in 2018.
Looking for additional help with MACRA and MIPS? Visit the Health Care Payment Reform Resource Center for insights and tools. Contact your BKD advisor for more information.