The Centers for Medicare & Medicaid Services (CMS) recently released its final rule for sweeping reimbursement regulations that start on Jan. 1, 2017.
Known as MACRA (the Medicare Access and CHIP Reauthorization Act of 2015), this legislation will have a profound impact on physicians and their practices.
On the plus side, the final rule softens some of the proposed regulations. This easing should help providers comply and thereby support CMS’s goals: to enhance care quality, reduce overall costs of care, and improve patient satisfaction. The best-performing providers will receive the greatest payment increases.
At the same time, eligible Medicare providers who have not yet prepared for MACRA should move quickly. Those who ignore the new reporting requirements completely -- by not submitting data to CMS -- will receive the full 4% payment penalty for 2017, and greater reductions thereafter.
MACRA establishes the Quality Payment Program (QPP), which offers providers a choice between two reporting tracks: the Merit-Based Incentive Payment System (MIPS) or Advanced Alternative Payment Model (Advanced APM).
Here are four major changes to the QPP under the MACRA final rule:
1. Establishment of 2017 as a “transition year” with reduced reporting requirements. For instance, CMS defined four paths providers can follow in 2017, each with a minimum performance threshold to avoid a payment penalty:
- Report under the MIPS track for 90 days;
- Report under MIPS for less than a year but more than 90 days, with reduced reporting requirements;
- Report under MIPS for the entire year but just one measure in each reporting category; or
- Participate in the Advanced APM track.
In addition, under the MIPS track, providers need only report one quality measure in 2017, rather than the six measures that will be required in future years (or one specialty-specific or subspecialty-specific measure set). Similarly, CMS has expanded the definition of “Improvement Activities” for 2017, to help providers meet these requirements.
2. Different thresholds for provider participation. The final rule raises the minimum amount of Medicare Part B charges that excuse providers from MIPS requirements -- from $10,000 or less under to the proposed rule, to $30,000 or less under the final rule. A second threshold – providers who see 100 or fewer Medicare patients – remains the same. Only one of these thresholds must be met to opt out of the QPP, but both must be met to participate in MIPS.
On the other hand, the final rule lowers the Advanced APM participation threshold from 25% of payments to 20%. The patient threshold remains at 25%.
3. Fewer measures required under the MIPS track. For instance, CMS reduced the Improvement Activities category from 60 to 40 possible points, and physicians can report one to four activities in 2017 (the transition year) rather than the proposed six.
In addition, CMS cut 2017 reporting requirements in the “Advancing Care Information” category from 11 proposed measures to five, all of which are related to use of electronic health records. (In 2018, Meaningful Use Stage 3 rules will apply.)
4. Reduced risk requirements for the Advanced APM track. Under the final rule, a provider can limit risk for 2017 and 2018 to 3% of the expected expenditures for which the provider is responsible under the APM alone – down from 4% under the proposed rule.
CMS withdrew proposed requirements for marginal risk and minimum loss ratio. However, such conditions will apply to “Other Payer” (non-Medicare) Advanced APMs starting in 2019.
The final rule also added an Advanced APM type for 2018: MSSP Track 1+. Other models are under consideration, with final determinations due by Jan. 1, 2017.While CMS has taken steps to smooth the transition to the QPP, the system remains complex, and each practice will need to determine its own path to success. To learn how Continuum Health Alliance can help your practice thrive under MACRA, please call (856) 782-3300 x2419 or email us at [email protected].