Linda Rouse O’Neill
By Linda Rouse O’Neill, Vice President, Government Affairs
You’ve likely heard the Centers for Medicare and Medicaid Services (CMS) released its final Medicare Access and CHIP Reauthorization Act (MACRA) rule. While the overall structure of the rule hasn’t changed – physicians will still need to choose one of two payment tracks – CMS made several changes to ease the transition for physicians.
These changes offer physicians breathing room, but the rule will continue to be top-of-mind. The payment track physicians select may ultimately entail higher financial risk, which could lead practices to take a closer look at their expenses.
MACRA highlights
Congress passed MACRA in an effort to prioritize high-quality patient care. CMS finalized two tracks physicians can choose to participate in:
- Merit-based Incentive Payment System (MIPS): MIPS builds on previous reporting programs with a focus on quality, cost, and use of certified EHR technology.
- Advanced Alternative Payment Models (Advanced APMs): An APM is a payment approach where physicians accept both risk and reward for providing coordinated, high quality, and efficient care.
CMS adjusts quality requirements for MIPS participants
Under the final rule, physicians will be required to report more data to CMS. This data, to be collected in 2017, will inform their MIPS score and, ultimately, shape their reimbursement in 2019. The MIPS score providers receive is based on four weighted domains:
- Quality
- Improvement activities
- Advancing care information
- Cost (or resource use)
The cost domain weighting was reduced from 10 percent to 0 for performance year 2017. As such, CMS will collect data on all four domains, but only the first three will determine the 2019 Medicare payments. To account for the 2017 cost domain reduction, quality weighting has been increased from 50 percent to 60 percent of the MIPS score. The cost domain will be reintroduced in the 2018 performance year.
CMS’s robust quality measures website (https://qpp.cms.gov/) provides detailed information on the hundreds of measures physicians can choose. It also walks physicians through the process of choosing measures for reporting purposes – something with which you can familiarize yourself and discuss with customers to offer products that can help improve outcomes and improve quality scores.
Physicians can pick their pace in 2017
CMS is allowing physicians to choose their participation level for the first performance period beginning Jan. 1, 2017.They have three options to submit data to MIPS, which are:
- Submit a Full Year: Report on the minimum number of measures required by CMS in each category to MIPS for at least one full 90-day period. By fully participating in the MIPS reporting program, physicians can maximize their chances to qualify for a positive adjustment during payment year 2019.
- Submit a Partial Year: Report to MIPS for a period of time less than the full year performance period, but for at least one full 90-day period. Performers must report either more than one quality measure, more than one improvement activity, or more than the required measures in the advancing care information performance category.
- Submit Something: Report one measure in the quality performance category, one activity in the improvement activities performance category, or the required measures of the advancing care information performance category.
Advanced APM participation
Alternately, physicians can participate in an Advanced APM. Participation in this payment track exempts physicians from MIPS reporting requirements. Additionally, if 25 percent of Medicare Part B payments or 20 percent of Medicare patients are received through an Advanced APM, physicians qualify for a 5 percent bonus incentive payment for 2019.
Exemptions
Many small practices will be exempt from these reporting requirements altogether due to low-volume threshold requirements. These are set at less than or equal to $30,000 in Medicare Part B allowed charges (or less than or equal to 100 Medicare patients). CMS predicts over 32% of physicians will meet this threshold.
Many of your physician customers may face substantially increased reporting requirements from the MACRA final rule. Keep in mind solutions you may be able to offer to address this burden. As always, feel free to contact us at HIDAGovAffairs@HIDA.org if you have any questions, or want more information.