It’s finally out. The final rule implementing the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was released today by CMS. In case you’ve been living under a rock, MACRA repeals the Medicare Sustainable Growth Rate (SGR) methodology for updates to the Physician Fee Schedule (PFS) and replaces it with a new approach to payment called the Quality Payment Program (QPP) that rewards the delivery of high-quality patient care through two mechanisms: Advanced Alternative Payment Models (Advanced APMs) and the Merit-based Incentive Payment System (MIPS) for eligible clinicians or groups under the PFS.
At Premier, we are eagerly scouring the pages to determine the implications of CMS’ final MACRA rule. But in case you haven’t gotten around to reading all 2,400 pages just yet, here are a few of our initial takeaways.
MACRA-eligible professionals will have more time to get ready for MACRA now that CMS has made 2017 a transition year that gives flexibility in terms of the number of measures and reporting periods required to comply. With the final rule, clinicians do not have to report a full year’s worth of data to MIPS in order to avoid a payment penalty. Instead, they can report on a 90-day period. They can also choose to report on a smaller subset of measures (1 quality measure or 1 clinical practice improvement activity, or 5 measures in advancing care information) in order to be in compliance. Cost, according to the final rule, will not be evaluated in 2017, and will be phased in over subsequent years. Of course, those that are further along can report more measures for a longer period of time, or they can participate in an Advanced APM to avoid MIPS and qualify for a 5 percent payment bonus.
CMS will provide $100 million in technical assistance to clinicians participating in MIPS who are in small practices, rural areas and areas with a shortage of health professionals. They’ve also increased the number of physicians that are exempted from the program due to low-volume, upping the floor from $10,000 in Medicare billed services to $30,000. Last, CMS has created an educational website with detailed resources on the MIPS and APM options, guidelines for small practices, as well as detailed fact sheets on the reporting requirements for the QPP.
CMS signaled that additional programs like bundled payments and an enhanced Track 1 (Track 1+) of the Medicare Shared Savings Program (MSSP) will be able to qualify as Advanced APMs and earn the 5 percent payment bonus. The devil will be in those details, however, as CMS punted on the exact requirements for how these programs will be altered in order to meet the high bar being set for qualified Advanced APMs. CMS also relaxed some of the risk assumption required to be an Advanced APM, lowering it to either 1) 8% of the average estimated total Medicare Parts A and B revenues of the participating entity or 2) 3% of the expected expenditures for which the APM is responsible. However, this still remains a very high risk threshold, and could have the unintended consequence of discouraging some from moving into Advanced APMs.
Confused? It’s OK…We’re Here to Help!
With MACRA comes great risk but great opportunity for hospitals and clinicians. Now is the time to accelerate your pace and differentiate your organization as a leader in value-based payment.
Premier is committed to helping providers get ahead of MACRA and start winning incentive payments. We strongly urge providers to work with a partner that can help them develop a roadmap for success with MACRA. Here are some things to consider:
- Do you understand your financial exposure and opportunity?
- How are you working to improve your physician enterprise’s productivity?
- Have you determined which measures to use and how best to report them?
- How are you leveraging MACRA to expand your business opportunities?
- Have you identified which APMs to consider and why?
- Do you know how to monitor and improve your performance on the measures?
To help you better understand the rule, register today for Premier’s Advisor Live session on November 2 to learn more about the specific provisions in the final rule. If you need additional guidance, our population health experts can assist in a more complete MACRA roadmap for your organization. Like I said… we’re here to help!
- CMS Final MACRA Rule
- CMS MACRA Press Release
- CMS MACRA Education Website
- CMS Blog Post by Andy Slavitt on MACRA
- Premier June 2016 MACRA Comments
MACRA Must Reads:
- Premier Statement on MACRA Final Rule
- Premier MACRA Whitepaper
- Premier Statement on Andy Slavitt MACRA Blog Post
- Six Big Trends To Watch In Health Care For 2016
- Potential MACRA Byproduct: Physician Consolidation
- The Journey: How to Stay Informed as Medicare Changes
- Few Docs Ready for Risk Under MACRA
- Here Are the MACRA Questions Every Healthcare Provider Must Ask
- Hospitals, Physicians Can Benefit From Collaboration Under MACRA
- What’s Best for Medicare Docs? Healthcare Policy Experts Weigh in on MACRA Payment Tracks
- MACRA Physician Payment Reform: Board Considerations for Strategy, Financial Risk, and Physician Alignment