CMS’s proposed rule for the Medicare Access and CHIP Reauthorization Act (MACRA) aims to create two quality payment tracks for Medicare reimbursement: the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs).
While MACRA’s proponents assure us that it will simplify the conditions for earning Medicare payments and ultimately reduce demands on participants, it seems that the dual tracks are creating some real apprehension in the healthcare community.
“Most physicians look at the ‘value-based’ payment reforms being brought by MACRA with a degree of trepidation,” writes Bob Doherty, senior vice president, governmental affairs and public policy, American College of Physicians. “They aren’t sure how to proceed, what measures will be used, whether they will be unfairly penalized for things outside of their control, and worried it will result in more administrative ‘hassles.’”
And according to eHealth Initiative CEO Jennifer Covich Bordenick, MACRA isn’t so simple. In her response to Andy Slavitt, CMS’s acting administrator, she writes, “The proposed regulation is overall too complex, intricate and difficult to understand with the challenge of multiple reporting channels. Importantly, this complexity could significantly impact the ability of some to participate in the new and expanded initiatives outlined in the rule, such as small physician practices, which CMS itself forecasts are much more likely to face MIPS payment cuts. Another look at simplification is strongly urged.”
If you’re a clinician and feeling these anxieties yourself, here are five key things you can do to get ready for that day in January 2017 when your first reporting period officially begins.
- Stay current with the timeline. CMS intends to make its criteria for physician-focused payment models, and its annual list of MIPS quality measures, public by November 1. Since CMS rarely hesitates to push back deadlines, it’s important that you monitor the latest CMS-website updates and breaking news developments to ensure that your timing is in lock step with theirs. A November 1 publication date will give eligible clinicians and vendors just a matter of weeks to get their reporting strategy in order, but if CMS happens to push that date back, you’ll likely want to take advantage of the extra time.
- Pick the right track. While most clinicians will record under MIPS, just a fraction of those will apply for one of the APM models. These models include Shared Savings Plan Tracks 2 and 3, the Comprehensive ESRD Care Model, the Next Generation ACO Model, the Comprehensive Primary Care Plus model, and, in 2018, the ONC Oncology Care But remember, at a minimum, you must first ensure you meet MIPS, just in case you don’t meet the criteria for an APM model. Otherwise, you may be penalized with a negative payment adjustment.
- Keep focusing on quality. While quality is always job #1, CMS is putting an extra premium on it in year #1. “The quality category accounts for 50 percent of the MIPS score in the first year,” notes CMS, with the other fifty percent determined by resource use, clinical practice improvement activities, and advanced care information (previously known as meaningful use). Again, while I’m sure you always focus on quality, you’re now being incentivized to show evidence of how you do it.
- Know how your specialty affects what you monitor. “Clinicians may also choose to report a specialty measure set—which are specifically designed around certain conditions and specialty-types,” notes CMS. That means you can vary your measures year to year, depending on your patient demographics and what you're trying to monitor. In that first year, determine if you’re going to submit individually or as part of a group first, and then identify exactly which quality measures will be appropriate to monitor.
- Prepare to document all of your achievements. While a “MIPS-eligible clinician has the option to measure performance as an individual, as a group defined by taxpayer identification number (TIN), or as a MIPS APM Entity using the APM scoring standard,” writes healthcare consultant Martie Ross, all four categories mentioned in #3 above “must be measured using the same classification.” Additionally, “a TIN/NPI’s CPS (composite performance score) may be based on individual, group, or APM Entity group performance, but the payment adjustment will be made at the individual TIN/NPI level.”
Either way, it’s up to you—not your group—to ensure that you’re complying with CMS’s standards and adding to the longitudinal patient record, which enables better healthcare through shared information and decision-making. By providing as much information as possible—including details of clinical practice improvement activities like care coordination, beneficiary engagement, and patient safety—a clinician can increase their chances for maximum positive adjustments, which will reach nine percent by 2022, a five-percent increase over the first year’s maximum.
While MACRA may be creating some worry among members of the healthcare community, don’t count yourself among them.
Instead, resolve to embrace MACRA for what it is: an effort to reward the healthcare industry’s best contributors by incentivizing them to give better care instead of merely more care, a true alternative to the sustainable growth rate’s broadly panned method for setting fees, and an opportunity for quality physicians and physician groups to counter the annual threat of payment cuts they’ve long endured with an annual chance for the bonuses they’ve long deserved.
Learn about the challenges Scottsdale Health Partners faced as a physician group and what they did to overcome them. Watch the video now!